2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.