Dear Mr. Waguespack, Thank you for the opportunity to respond to your office’s findings related to the Special Tests and Provisions Requirements. Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) has reviewed the issues identified by your staff. During this period, the insti...
Dear Mr. Waguespack, Thank you for the opportunity to respond to your office’s findings related to the Special Tests and Provisions Requirements. Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) has reviewed the issues identified by your staff. During this period, the institution was modernizing its Time & Effort framework via PeopleSoft, implementing revised PER (personnel change request) routing, and establishing a post-award monitoring process. LSUHSC-S concurs with your recommendations for addressing the finding. The timeliness issues identified in the key control have been addressed, and corrective actions have been implemented to ensure proper functioning going forward. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should also ensure the Time & Effort monitoring forms are completed timely to ensure compliance with Special Tests & Provisions requirements. Response and Corrective Action Plan LSUHSC-S is continuing to strengthen the management, internal controls, and efficiency of sponsored programs management. We have now established our Managing Effort policy to clarify that cost share is required if committed effort is not being charged to a project budget for any reason. We also modified our Cayuse award routing to include the Budget Office and General Accounting if the award record indicates that there will be any institutional cost sharing. This process is now automated and will ensure the setup of cost share accounts is incorporated into the account setup process, where it was a separate and “after the fact” process previously. Additionally, LSUHSC-S will implement a PI Eligibility Policy preventing gratis faculty from serving as PIs in the future. Time & Effort Certifications: LSUHSC-S implemented the PeopleSoft Time & Effort certification system in January 2025, with quarterly certifications for biweekly employees and semiannual certifications for monthly employees. These certifications are the official after-the-fact documentation required by 2 CFR 200. Related institutional directives—AD 4.4 (Time & Effort Reporting Certification) and AD 4.10 (Effort Commitment – Managing Effort on Sponsored Projects)—were revised with an effective date of July 1, 2025, and accompanied by FAQs and distributed training/guidance to campus stakeholders. Importantly, each of the 8 exceptions for the key control had timely official PeopleSoft effort certifications. Quarterly Effort Monitoring Tool (Key Control): Quarterly Effort Monitoring spreadsheets are used as the key control for monitoring effort prior to certification. This quarterly review provides an essential, structured “point in time” checkpoint that allows PIs and departments to identify discrepancies early and correct them before the official PeopleSoft effort certification is finalized. The control issues identified during the audit period were attributable to early-stage implementation of new systems and processes. LSUHSC-S has taken corrective action in several areas, including automating the workflow via AdobeSign, assigning a dedicated staff member to monitor the process, and incorporating escalation procedures to ensure timely return of the monitoring tool. Per our Effort Commitment — Managing Effort policy, quarterly reviews are one monitoring tool among several, including monthly ledger reviews by departments, and PER reviews, where any effort reallocation routes to OSP Post Award for assessment of sponsor rules and prior-approval needs prior to approving the change institutionally. While these complimentary controls support the overall monitoring structure, they do not replace the Quarterly Effort Review Spreadsheet as the key control. Prior Approval Improvements: To strengthen compliance with 2 CFR 200.308, LSUHSC-S implemented the electronic InfoReady Change in Senior/Key Personnel Request on May 1, 2025, now the primary tool for routing prior-approval requests. Integration with PER3 ensures OSP Post Award can deny personnel changes until sponsor approval is obtained. Automated reminders began April 1, 2025. Name of Contacts Responsible for Action Plan: Ramey Benfield, Chief Financial Officer & Vice Chancellor for Finance and Administration Ashley Krukowski, Executive Director, Office for Sponsored Programs Valarie White, Director, Office for Sponsored Programs, Pre-Award Administration Tracy Calvert, Director, Office for Sponsored Programs, Post Award Administration Estimated Completion Date: June 30th, 2026 Conclusion LSUHSC-S considers that the implementation of the PeopleSoft effort certification system, revised effort and cost transfer directives, the InfoReady prior-approval workflow, and automation of the Quarterly Effort Monitoring tool will address the auditors’ concerns and provide a strong, sustainable compliance framework that will be further demonstrated in the next audit cycle. If you have any questions or require additional information, please contact me at 318-675-6327 or via email at ramey.benfield@lsuhs.edu.