Audit 53797

Criteria 2 CFR 200.305 (b3): Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition In testing compliance with the cash management compliance requirement, specifically the reimbursement-method, 40 individual expenditures were tested to compare the date the University made payment to a vendor for a selected expense transaction to the date the University requested sponsor reimbursement for the same transaction. Seven instances were noted in which the University paid the vendor after requesting and receiving reimbursement from the government, as shown in the chart below. See Schedule of Findings and Questioned Costs for chart/table This is a repeat of finding 2021-001, 2020-001, 2019-001, 2018-002 and 2017-002 in prior year audit reports. Cause Management?s current process to ensure that the reimbursement of expenditures occurs only after paying the vendor utilizes the assumption that vendors will be paid within 30 days, on average, of incurring the expense. Effect The University received Federal reimbursement prior to paying the vendors for the selected expenses. The reliance of the 30 day average time-frame allowed certain expenditures to be included in requests for reimbursement prior to being liquidated. Questioned Costs None as reimbursement was requested for allowable costs. Recommendation The University should revisit existing internal control procedures to ensure expenditures are paid in compliance with the Federal reimbursement requirements. We also recommend management discuss current cash management requirements with the OMB and the University?s cognizant agency to determine a solution that meets the needs of both parties. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.

Criteria Per 2 CFR section 180.220, non-federal entities are prohibited from contracting with or making subawards under covered transactions, where vendor purchases exceed $25,000, to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction, the non-federal entity must verify that the vendor is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the Vendor, or (3) adding a clause or condition to the covered transaction with that Vendor. University?s policies mirror the procurement policies as required by the Federal government, and defines a covered transaction as purchases exceeding $10,000. Condition In testing compliance with the suspension and debarment compliance requirement, 1 instance of 25 samples selected for testing was noted where the only evidence available to support the date of the performance of the required suspension and debarment checks was after the transaction date, as shown in the chart below. See Schedule of Findings and Questioned Costs for chart/table Cause The University uses Visual Compliance (VC) for suspension and debarment checks, which was implemented in 2019. Vendors onboarded prior to the implementation were registered and checked via a separate manual process within the procurement department. The above vendor was on-boarded and checked prior to the VC implementation; however, management could not provide evidence that a vendor check was performed prior to conducting business with the vendor due to the manual nature of the legacy process. Management has subsequently performed checks on this vendor and retained documentation of the checks to validate that the vendor is not currently suspended or debarred. Effect If procedures related to vendor suspended and debarred checks are not performed timely, there is a risk that the purchases could be made with a suspended or debarred vendor. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University further enhance related documentation procedures for evaluating suspended or debarred vendors. Prior to making payments to a vendor, the University should document the review of the vendor to ensure checks are performed timely with proper documentation to evidence the outcome of the vendor review process. Views of responsible officials and planned corrective actions Following this finding is Management?s View and Corrective Action Plan.

Criteria 2 CFR 200.305 (b3): Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition In testing compliance with the cash management compliance requirement, specifically the reimbursement-method, 40 individual expenditures were tested to compare the date the University made payment to a vendor for a selected expense transaction to the date the University requested sponsor reimbursement for the same transaction. Seven instances were noted in which the University paid the vendor after requesting and receiving reimbursement from the government, as shown in the chart below. See Schedule of Findings and Questioned Costs for chart/table This is a repeat of finding 2021-001, 2020-001, 2019-001, 2018-002 and 2017-002 in prior year audit reports. Cause Management?s current process to ensure that the reimbursement of expenditures occurs only after paying the vendor utilizes the assumption that vendors will be paid within 30 days, on average, of incurring the expense. Effect The University received Federal reimbursement prior to paying the vendors for the selected expenses. The reliance of the 30 day average time-frame allowed certain expenditures to be included in requests for reimbursement prior to being liquidated. Questioned Costs None as reimbursement was requested for allowable costs. Recommendation The University should revisit existing internal control procedures to ensure expenditures are paid in compliance with the Federal reimbursement requirements. We also recommend management discuss current cash management requirements with the OMB and the University?s cognizant agency to determine a solution that meets the needs of both parties. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.

Criteria 2 CFR 200.305 (b3): Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition In testing compliance with the cash management compliance requirement, specifically the reimbursement-method, 40 individual expenditures were tested to compare the date the University made payment to a vendor for a selected expense transaction to the date the University requested sponsor reimbursement for the same transaction. Seven instances were noted in which the University paid the vendor after requesting and receiving reimbursement from the government, as shown in the chart below. See Schedule of Findings and Questioned Costs for chart/table This is a repeat of finding 2021-001, 2020-001, 2019-001, 2018-002 and 2017-002 in prior year audit reports. Cause Management?s current process to ensure that the reimbursement of expenditures occurs only after paying the vendor utilizes the assumption that vendors will be paid within 30 days, on average, of incurring the expense. Effect The University received Federal reimbursement prior to paying the vendors for the selected expenses. The reliance of the 30 day average time-frame allowed certain expenditures to be included in requests for reimbursement prior to being liquidated. Questioned Costs None as reimbursement was requested for allowable costs. Recommendation The University should revisit existing internal control procedures to ensure expenditures are paid in compliance with the Federal reimbursement requirements. We also recommend management discuss current cash management requirements with the OMB and the University?s cognizant agency to determine a solution that meets the needs of both parties. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.

Criteria 2 CFR 200.305 (b3): Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition In testing compliance with the cash management compliance requirement, specifically the reimbursement-method, 40 individual expenditures were tested to compare the date the University made payment to a vendor for a selected expense transaction to the date the University requested sponsor reimbursement for the same transaction. Seven instances were noted in which the University paid the vendor after requesting and receiving reimbursement from the government, as shown in the chart below. See Schedule of Findings and Questioned Costs for chart/table This is a repeat of finding 2021-001, 2020-001, 2019-001, 2018-002 and 2017-002 in prior year audit reports. Cause Management?s current process to ensure that the reimbursement of expenditures occurs only after paying the vendor utilizes the assumption that vendors will be paid within 30 days, on average, of incurring the expense. Effect The University received Federal reimbursement prior to paying the vendors for the selected expenses. The reliance of the 30 day average time-frame allowed certain expenditures to be included in requests for reimbursement prior to being liquidated. Questioned Costs None as reimbursement was requested for allowable costs. Recommendation The University should revisit existing internal control procedures to ensure expenditures are paid in compliance with the Federal reimbursement requirements. We also recommend management discuss current cash management requirements with the OMB and the University?s cognizant agency to determine a solution that meets the needs of both parties. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.

Criteria 2 CFR 200.305 (b3): Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition In testing compliance with the cash management compliance requirement, specifically the reimbursement-method, 40 individual expenditures were tested to compare the date the University made payment to a vendor for a selected expense transaction to the date the University requested sponsor reimbursement for the same transaction. Seven instances were noted in which the University paid the vendor after requesting and receiving reimbursement from the government, as shown in the chart below. See Schedule of Findings and Questioned Costs for chart/table This is a repeat of finding 2021-001, 2020-001, 2019-001, 2018-002 and 2017-002 in prior year audit reports. Cause Management?s current process to ensure that the reimbursement of expenditures occurs only after paying the vendor utilizes the assumption that vendors will be paid within 30 days, on average, of incurring the expense. Effect The University received Federal reimbursement prior to paying the vendors for the selected expenses. The reliance of the 30 day average time-frame allowed certain expenditures to be included in requests for reimbursement prior to being liquidated. Questioned Costs None as reimbursement was requested for allowable costs. Recommendation The University should revisit existing internal control procedures to ensure expenditures are paid in compliance with the Federal reimbursement requirements. We also recommend management discuss current cash management requirements with the OMB and the University?s cognizant agency to determine a solution that meets the needs of both parties. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.

Criteria 2 CFR 200.305 (b3): Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition In testing compliance with the cash management compliance requirement, specifically the reimbursement-method, 40 individual expenditures were tested to compare the date the University made payment to a vendor for a selected expense transaction to the date the University requested sponsor reimbursement for the same transaction. Seven instances were noted in which the University paid the vendor after requesting and receiving reimbursement from the government, as shown in the chart below. See Schedule of Findings and Questioned Costs for chart/table This is a repeat of finding 2021-001, 2020-001, 2019-001, 2018-002 and 2017-002 in prior year audit reports. Cause Management?s current process to ensure that the reimbursement of expenditures occurs only after paying the vendor utilizes the assumption that vendors will be paid within 30 days, on average, of incurring the expense. Effect The University received Federal reimbursement prior to paying the vendors for the selected expenses. The reliance of the 30 day average time-frame allowed certain expenditures to be included in requests for reimbursement prior to being liquidated. Questioned Costs None as reimbursement was requested for allowable costs. Recommendation The University should revisit existing internal control procedures to ensure expenditures are paid in compliance with the Federal reimbursement requirements. We also recommend management discuss current cash management requirements with the OMB and the University?s cognizant agency to determine a solution that meets the needs of both parties. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.

Criteria 2 CFR 200.305 (b3): Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition In testing compliance with the cash management compliance requirement, specifically the reimbursement-method, 40 individual expenditures were tested to compare the date the University made payment to a vendor for a selected expense transaction to the date the University requested sponsor reimbursement for the same transaction. Seven instances were noted in which the University paid the vendor after requesting and receiving reimbursement from the government, as shown in the chart below. See Schedule of Findings and Questioned Costs for chart/table This is a repeat of finding 2021-001, 2020-001, 2019-001, 2018-002 and 2017-002 in prior year audit reports. Cause Management?s current process to ensure that the reimbursement of expenditures occurs only after paying the vendor utilizes the assumption that vendors will be paid within 30 days, on average, of incurring the expense. Effect The University received Federal reimbursement prior to paying the vendors for the selected expenses. The reliance of the 30 day average time-frame allowed certain expenditures to be included in requests for reimbursement prior to being liquidated. Questioned Costs None as reimbursement was requested for allowable costs. Recommendation The University should revisit existing internal control procedures to ensure expenditures are paid in compliance with the Federal reimbursement requirements. We also recommend management discuss current cash management requirements with the OMB and the University?s cognizant agency to determine a solution that meets the needs of both parties. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.

Criteria Per 2 CFR section 180.220, non-federal entities are prohibited from contracting with or making subawards under covered transactions, where vendor purchases exceed $25,000, to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction, the non-federal entity must verify that the vendor is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the Vendor, or (3) adding a clause or condition to the covered transaction with that Vendor. University?s policies mirror the procurement policies as required by the Federal government, and defines a covered transaction as purchases exceeding $10,000. Condition In testing compliance with the suspension and debarment compliance requirement, 1 instance of 25 samples selected for testing was noted where the only evidence available to support the date of the performance of the required suspension and debarment checks was after the transaction date, as shown in the chart below. See Schedule of Findings and Questioned Costs for chart/table Cause The University uses Visual Compliance (VC) for suspension and debarment checks, which was implemented in 2019. Vendors onboarded prior to the implementation were registered and checked via a separate manual process within the procurement department. The above vendor was on-boarded and checked prior to the VC implementation; however, management could not provide evidence that a vendor check was performed prior to conducting business with the vendor due to the manual nature of the legacy process. Management has subsequently performed checks on this vendor and retained documentation of the checks to validate that the vendor is not currently suspended or debarred. Effect If procedures related to vendor suspended and debarred checks are not performed timely, there is a risk that the purchases could be made with a suspended or debarred vendor. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University further enhance related documentation procedures for evaluating suspended or debarred vendors. Prior to making payments to a vendor, the University should document the review of the vendor to ensure checks are performed timely with proper documentation to evidence the outcome of the vendor review process. Views of responsible officials and planned corrective actions Following this finding is Management?s View and Corrective Action Plan.

Criteria 2 CFR 200.305 (b3): Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition In testing compliance with the cash management compliance requirement, specifically the reimbursement-method, 40 individual expenditures were tested to compare the date the University made payment to a vendor for a selected expense transaction to the date the University requested sponsor reimbursement for the same transaction. Seven instances were noted in which the University paid the vendor after requesting and receiving reimbursement from the government, as shown in the chart below. See Schedule of Findings and Questioned Costs for chart/table This is a repeat of finding 2021-001, 2020-001, 2019-001, 2018-002 and 2017-002 in prior year audit reports. Cause Management?s current process to ensure that the reimbursement of expenditures occurs only after paying the vendor utilizes the assumption that vendors will be paid within 30 days, on average, of incurring the expense. Effect The University received Federal reimbursement prior to paying the vendors for the selected expenses. The reliance of the 30 day average time-frame allowed certain expenditures to be included in requests for reimbursement prior to being liquidated. Questioned Costs None as reimbursement was requested for allowable costs. Recommendation The University should revisit existing internal control procedures to ensure expenditures are paid in compliance with the Federal reimbursement requirements. We also recommend management discuss current cash management requirements with the OMB and the University?s cognizant agency to determine a solution that meets the needs of both parties. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.

Criteria 2 CFR 200.305 (b3): Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition In testing compliance with the cash management compliance requirement, specifically the reimbursement-method, 40 individual expenditures were tested to compare the date the University made payment to a vendor for a selected expense transaction to the date the University requested sponsor reimbursement for the same transaction. Seven instances were noted in which the University paid the vendor after requesting and receiving reimbursement from the government, as shown in the chart below. See Schedule of Findings and Questioned Costs for chart/table This is a repeat of finding 2021-001, 2020-001, 2019-001, 2018-002 and 2017-002 in prior year audit reports. Cause Management?s current process to ensure that the reimbursement of expenditures occurs only after paying the vendor utilizes the assumption that vendors will be paid within 30 days, on average, of incurring the expense. Effect The University received Federal reimbursement prior to paying the vendors for the selected expenses. The reliance of the 30 day average time-frame allowed certain expenditures to be included in requests for reimbursement prior to being liquidated. Questioned Costs None as reimbursement was requested for allowable costs. Recommendation The University should revisit existing internal control procedures to ensure expenditures are paid in compliance with the Federal reimbursement requirements. We also recommend management discuss current cash management requirements with the OMB and the University?s cognizant agency to determine a solution that meets the needs of both parties. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.

Criteria 2 CFR 200.305 (b3): Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition In testing compliance with the cash management compliance requirement, specifically the reimbursement-method, 40 individual expenditures were tested to compare the date the University made payment to a vendor for a selected expense transaction to the date the University requested sponsor reimbursement for the same transaction. Seven instances were noted in which the University paid the vendor after requesting and receiving reimbursement from the government, as shown in the chart below. See Schedule of Findings and Questioned Costs for chart/table This is a repeat of finding 2021-001, 2020-001, 2019-001, 2018-002 and 2017-002 in prior year audit reports. Cause Management?s current process to ensure that the reimbursement of expenditures occurs only after paying the vendor utilizes the assumption that vendors will be paid within 30 days, on average, of incurring the expense. Effect The University received Federal reimbursement prior to paying the vendors for the selected expenses. The reliance of the 30 day average time-frame allowed certain expenditures to be included in requests for reimbursement prior to being liquidated. Questioned Costs None as reimbursement was requested for allowable costs. Recommendation The University should revisit existing internal control procedures to ensure expenditures are paid in compliance with the Federal reimbursement requirements. We also recommend management discuss current cash management requirements with the OMB and the University?s cognizant agency to determine a solution that meets the needs of both parties. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.

Criteria 2 CFR 200.305 (b3): Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition In testing compliance with the cash management compliance requirement, specifically the reimbursement-method, 40 individual expenditures were tested to compare the date the University made payment to a vendor for a selected expense transaction to the date the University requested sponsor reimbursement for the same transaction. Seven instances were noted in which the University paid the vendor after requesting and receiving reimbursement from the government, as shown in the chart below. See Schedule of Findings and Questioned Costs for chart/table This is a repeat of finding 2021-001, 2020-001, 2019-001, 2018-002 and 2017-002 in prior year audit reports. Cause Management?s current process to ensure that the reimbursement of expenditures occurs only after paying the vendor utilizes the assumption that vendors will be paid within 30 days, on average, of incurring the expense. Effect The University received Federal reimbursement prior to paying the vendors for the selected expenses. The reliance of the 30 day average time-frame allowed certain expenditures to be included in requests for reimbursement prior to being liquidated. Questioned Costs None as reimbursement was requested for allowable costs. Recommendation The University should revisit existing internal control procedures to ensure expenditures are paid in compliance with the Federal reimbursement requirements. We also recommend management discuss current cash management requirements with the OMB and the University?s cognizant agency to determine a solution that meets the needs of both parties. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.

Criteria 2 CFR 200.305 (b3): Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition In testing compliance with the cash management compliance requirement, specifically the reimbursement-method, 40 individual expenditures were tested to compare the date the University made payment to a vendor for a selected expense transaction to the date the University requested sponsor reimbursement for the same transaction. Seven instances were noted in which the University paid the vendor after requesting and receiving reimbursement from the government, as shown in the chart below. See Schedule of Findings and Questioned Costs for chart/table This is a repeat of finding 2021-001, 2020-001, 2019-001, 2018-002 and 2017-002 in prior year audit reports. Cause Management?s current process to ensure that the reimbursement of expenditures occurs only after paying the vendor utilizes the assumption that vendors will be paid within 30 days, on average, of incurring the expense. Effect The University received Federal reimbursement prior to paying the vendors for the selected expenses. The reliance of the 30 day average time-frame allowed certain expenditures to be included in requests for reimbursement prior to being liquidated. Questioned Costs None as reimbursement was requested for allowable costs. Recommendation The University should revisit existing internal control procedures to ensure expenditures are paid in compliance with the Federal reimbursement requirements. We also recommend management discuss current cash management requirements with the OMB and the University?s cognizant agency to determine a solution that meets the needs of both parties. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.