The University acknowledges the audit finding and remains committed to maintaining compliance with the cash
management requirements outlined in 2 CFR 200.302(b)(3), which stipulates that recipients must maintain records that
sufficiently identify Federal awards and ensure that drawdowns are properly...
The University acknowledges the audit finding and remains committed to maintaining compliance with the cash
management requirements outlined in 2 CFR 200.302(b)(3), which stipulates that recipients must maintain records that
sufficiently identify Federal awards and ensure that drawdowns are properly supported and authorized prior to
submission.
During the audit period, the University experienced a transition in leadership within the Office of Research
Administration. As part of this transition, the Associate Vice President for Research Administration was responsible for
reviewing and approving drawdown requests. However, due to staffing adjustments and process changes during this
period, at least two drawdowns were processed without prior approval from the Associate Vice President. Additionally, at
least one drawdown was approved retroactively after submission.
To address these issues and strengthen compliance, the University has implemented several corrective actions. A new
Assistant Vice President of Post-Award Services and Financial Compliance has been hired on January 8, 2024 to provide
dedicated oversight and ensure adherence to compliance standards. Furthermore, the Executive Director of Cash
Management, the Assistant Vice President of Post-Award Services and Financial Compliance, and the Associate Vice
President of Research Administration have all received targeted training in May of 2024 to reinforce the requirement for
supervisory approval prior to drawdown submission. The University has also conducted a comprehensive review of its
cash management processes, implementing enhanced internal controls to ensure all drawdown requests are reviewed,
verified, and approved by designated leadership before submission. Lastly, a formalized transition plan has been
developed to ensure continuity and compliance during future changes in leadership if such events were to occur.
These corrective actions underscore the University’s commitment to maintaining the accuracy and integrity of its financial
management processes. While no questioned costs were identified, the steps outlined above will help ensure ongoing
compliance with Federal cash management requirements.
Primary responsibility for implementing the correction action plan for this finding rests with Angela Tagliaferri, Assistant
Vice President of Post-Award Services and Financial Compliance, 216-368-6269.