MANAGEMENT VIEWS AND CORRECTIVE ACTION PLAN REPORT ON FEDERAL AWARDS IN ACCORDANCE WITH THE OMB UNIFORM GUIDANCE SEPTEMBER 30, 2022 Finding 2022-001 Subrecipient Monitoring To ensure Auburn University is in compliance with 2 CFR 200.332(b), 2 CFR200.332 (d), 2CFR 200.332 (e), and 2CFR (f). Aubu...
MANAGEMENT VIEWS AND CORRECTIVE ACTION PLAN REPORT ON FEDERAL AWARDS IN ACCORDANCE WITH THE OMB UNIFORM GUIDANCE SEPTEMBER 30, 2022 Finding 2022-001 Subrecipient Monitoring To ensure Auburn University is in compliance with 2 CFR 200.332(b), 2 CFR200.332 (d), 2CFR 200.332 (e), and 2CFR (f). Auburn University will implement the following corrective action plan: The Office of Sponsored Programs will 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. The Office of Sponsored Programs has begun addressing this issue by enhancing the existing Subagreement Checklist utilized at the beginning of the subaward set-up. The new checklist provides a place for documenting the judgment around whether a new risk assessment should be performed, the results of the audit review, and the results of any necessary risk assessments. It also provides an opportunity for the administrator to detail the reasons for the risk assessment results. These documents will be monitored by the lead subaward administrator before the subaward is fully executed. Once reviewed, the lead subaward administrator will date and sign the checklist as verification that all applicable monitoring has been performed and gone through a two-step review process. The results will then be added to a master list that will be utilized when pulling the audit reports on a yearly basis for review. The checklist will be accompanied by a guide to completing the form and the regulatory backup for each applicable step. The Office of Sponsored Programs will 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. These procedures include (among other items) obtaining a certification letter or current audit from the subrecipient and performing an annual risk assessment on all subrecipients. Auburn University has also engaged in the implementation of an electronic research administration (eRA) solution that will include a subaward module. We expect the eRA system to be fully operational during the first quarter of fiscal year 2025. Additionally, the Office of Sponsored Programs is currently reviewing the required staffing levels to ensure the timely implementation and operation of the above-referenced procedures. Contact: Tony Ventimiglia Asst. VP for Research Administration, Office of the Senior VP for Research & Economic Development Amy Douglas Assoc. VP Financial Services/Controller Anticipated Completion Date: July 31, 2023