Dear Mr. Waguespack, Please find below the University's management response to the audit finding titled "Control Weakness and Noncompliance with Special Tests and Provisions Requirements." Management Response The University concurs with the finding. This letter is provided in response to the audit f...
Dear Mr. Waguespack, Please find below the University's management response to the audit finding titled "Control Weakness and Noncompliance with Special Tests and Provisions Requirements." Management Response The University concurs with the finding. This letter is provided in response to the audit finding related to Special Tests and Provisions requirements. The audit identified that UL Lafayette did not have adequately designed controls to ensure compliance with federal award requirements related to key personnel effort. Specifically, the auditors noted that key personnel were not involved in the project at the level required by the federal award or proposal submissions, prior approvals for changes in effort were not obtained from the federal grantor agency or pass-through entity when required, and time and effort certifications for key personnel were not sufficient to certify that the required level of effort was met. Additionally, the audit determined that UL Lafayette did not have adequate controls in place to monitor key personnel effort on a timely basis to ensure required effort levels were maintained and that prior written approvals were obtained when applicable. The auditors further noted that annual and semiannual certifications alone were not sufficient to timely detect changes in key personnel effort that would require prior approval. Our primary focus has been on ensuring that salaries charged to sponsored projects were accurate and did not exceed approved budgetary limits as required by sponsors. We are actively developing and implementing a documented procedure for effort reporting to address this issue going forward. Corrective Action Plan Dr. Kumer Das, the Interim Vice President of Research, Innovation and Economic Development will be responsible with overseeing all corrective actions to address this finding and strengthen compliance with federal key personnel effort monitoring requirements. The following corrective actions have been implemented or are in progress: 1. Realignment of Research Administration Functions • Effective May 29, 2025, pre-award and post-award operations were consolidated under the Vice President for Research. This structural realignment strengthens oversight, improves coordination of proposal commitments and post-award monitoring, and enhances accountability across the grant lifecycle. 2. Comprehensive Business Process Mapping • The University engaged Ellucian to conduct a comprehensive review of end-to-end grant management workflows. This process mapping initiative evaluated roles, responsibilities, and control points related to proposal development, award setup, payroll distribution, and effort certification. Knowledge transfer sessions have been scheduled for March and April 2026 with Ellucian consultants to support implementation of revised procedures and internal control enhancements. 3. Effort Tracking, Reconciliation, and Certification To address the identified deficiencies, the University is implementing the following control enhancements: • Pre-Award Commitment Review: At the time of proposal submission, Pre-Award staff will review and document key personnel effort commitments to ensure proposed effort is reasonable, attainable, and aligned with institutional responsibilities. A centralized key personnel commitment tracker is under development and will be implemented by March 31, 2026. • Award-Level Commitment Reconciliation: Upon receipt of an award, the tracker will be updated to reflect sponsor-approved effort commitments. This will establish the baseline for post-award monitoring. • Quarterly or Semester-Based Effort Reviews: In addition to formal bi-annual certification cycles, the University will implement quarterly or semester-based internal effort reviews to provide timely identification of changes in key personnel commitment levels. The revised Standard Operating Procedure (SOP) will reflect this change. • Ongoing Monitoring and Payroll Reconciliation: Based on effort reviews, Post-Award will perform reconciliations of payroll charges and compare actual effort to committed effort levels. Variances will be reviewed with the Principal Investigator. Where reductions in effort exceed sponsor thresholds (e.g., greater than 25% reduction or disengagement exceeding three months), the Office of Research Administration and Compliance (ORAC) will determine whether prior approval or sponsor notification is required and will document the resolution. The University remains committed to making continuous improvements and appreciates your understanding of support as we address these challenges.