Reference: Finding 2024-002 Access Restricted to Documentation for Various Compliance Requirements – Research & Development Cluster; Noncompliance – Period of Performance, Procurement (Micro Purchasing), Subrecipient Monitoring, and Equipment and Real Property Management
Contact: Erica Classing, C...
Reference: Finding 2024-002 Access Restricted to Documentation for Various Compliance Requirements – Research & Development Cluster; Noncompliance – Period of Performance, Procurement (Micro Purchasing), Subrecipient Monitoring, and Equipment and Real Property Management
Contact: Erica Classing, Controller; classinge@battelle.org; 614-424-3372
Views of Responsible Officials:
Battelle acknowledges this finding is the result of access restrictions to classified contract documents imposed by federal agencies that are beyond Battelle’s control. Battelle does not have the authority to grant auditor access to classified programs without the proper security clearance and program permissions, rather this authority resides with the federal awarding agency, in accordance with applicable federal security regulations. These restrictions prohibited access to classified contracts for required audit procedures in those areas noted in Finding 2024-002.
Classified contracts are a small subset (10%) of Battelle’s total reportable expenditures. Battelle provided all unclassified documentation required to support transactions selected for testing. In addition, Battelle provided all documentation necessary to audit compliance with requirements on all non-classified contracts selected.
Management upholds high standards of compliance and transparency and continues to support audit processes to the fullest extent possible. Battelle agrees to explore options to satisfy audit requirements while maintaining compliance with classified contract security regulations.
Corrective Action Plan:
Summary of finding:
During compliance testing of period of performance, procurement (micro purchasing), subrecipient monitoring, and equipment and real property management, access to classified contracts was restricted. The auditor was unable to view federal award documents to confirm the following information:
• Period of performance (5 of 50 selections) - unable to confirm the authorized project period
• Procurement (micro purchasing) (2 of 40 selections) - unable to review applicable requirement relating to consent to subcontract
• Subrecipient monitoring (2 out of 40 selections) – unable to inspect subaward information and applicable terms
• Equipment and real property management (3 out of 50 selections) – unable to obtain proof of active use and safeguard of the classified equipment and validate whether the equipment disposal was handled properly in accordance with the contractual terms and conditions.
Root cause:
Access to classified contracts is subject to confidentiality requirements mandated by external regulators, requiring appropriate security clearance levels and verified need-to-know status. If the classified contract is a special access program, obtaining program-specific approvals from the awarding agency in addition to possessing the appropriate security clearance and need to know is required. There is no guarantee that the federal awarding agency will ultimately grant cleared auditors access to the classified contract.
Corrective action:
Battelle is taking the following steps to address the finding:
• Internal Review: We conducted an internal review of the areas affected by the scope limitation to validate each selection complied with the applicable contractual and regulatory requirements. This action was completed by December 19, 2024 and did not identify any instance of non-compliance with applicable rules, regulations, or contractual requirements.
• We have existing monitoring mechanisms in place to ensure compliance in the areas affected by the scope limitation.
• Early coordination with external auditor: We are collaborating with our external audit team to identify any classified contract audit selections earlier in the annual audit process. A proactive approach will allow Battelle extra time to engage clients for required approvals to either gain access to the classified information or obtain appropriate alternative audit evidence. In addition, any other related steps that can be completed in advance such as verifying auditor clearance types and levels will be performed early to help mitigate any delays. This corrective action requires the audit firm to provide auditors with the appropriate security clearances.
• Engagement with regulatory agencies: We are in dialogue with impacted federal awarding agencies to explore options to provide necessary audit evidence.
• Enhanced documentation: We are enhancing our audit support procedures to provide guidelines on how, within the bounds of regulatory restrictions, we can provide access to audit evidence for future audits.
Overall Anticipated Implementation Date: December 31, 2025