Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
Finding 2022-066 Research and Development Cluster Subrecipient Monitoring Compliance Requirement The federal government sponsors research and development (R&D) activities under a variety of types of awards, most commonly grants, cooperative agreements, and contracts, to achieve objectives agreed upon between the federal awarding agency and the non-federal entity. The types of R&D conducted under these awards vary greatly. The objective of an individual project is explained in the federal award letter. R&D activities at the University are subject to federal subrecipient monitoring requirements. Under these requirements, the University is required to monitor its subrecipients to ensure they use funds in accordance with applicable laws, regulations and terms of the award. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Federal regulations [2 CFR 200.1] define a subaward as an award provided by a pass-through entity, in this case the University, to an entity to carry out part of a Federal grant award received by the pass-through entity. As part of its subrecipient monitoring process, the University uses a subrecipient monitoring checklist that includes a variety of checkpoints, including whether an approved budget is in place and reviewed: whether the subrecipient had an audit, if applicable, and whether that audit has been reviewed; and whether a risk assessment related to a subrecipient?s potential noncompliance has been performed. During Fiscal Year 2022, the University?s three campuses in total expended approximately $916 million in R&D grant funds: $504 million, $406 million, and $6 million from the Boulder, Denver, and UCCS campuses, respectively. The University passed approximately $120 million to 1,325 subrecipients including other universities and non-profit organizations, to assist in the performance of a wide-range of projects such as research into learning disabilities or the advancement of scientific discovery, or other research related projects. What was the purpose of our audit work and what work was performed? The purpose of the audit work was to determine whether the University?s campuses had adequate internal controls in place over, and complied with, the R&D?s subrecipient monitoring requirements for Fiscal Year 2022. As part of our audit work, we tested 40 subrecipients to determine whether the University campuses? performed the subrecipient risk assessments related to a subrecipient?s potential noncompliance as required by federal regulations. How were the results of the audit work measured? We measured the results of our audit work against the following requirements: ? Federal regulation 2 CFR 200.331(b) requires that the University?s campuses, as federal grant recipients, must ?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.? ? The Boulder campus? policy states that monitoring the subaward is a ?collaborative effort? made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.? Completion of a risk analysis and the subrecipient monitoring checklist is listed among the responsibilities of the Central Office. What problem did the audit work identify? The Boulder campus did not perform a risk assessment for six out of the 40 subrecipients we tested (15 percent). However, the campus did perform other monitoring procedures over these subrecipients as the risk assessment process is one procedure in the overall subrecipient monitoring process. Why did this problem occur? The University did not have adequate internal controls in place for monitoring its subrecipients. Specifically, the University?s Boulder campus did not ensure that staff reviewed the subrecipient monitoring checklist in all instances to ensure all appropriate steps were completed, including risk assessments. University personnel indicated that proper staffing was not in place and specific monitoring of risk assessments was not being performed. Why does this problem matter? The University is obligated to adhere to specified requirements as outlined in federal regulations and the respective award agreement. By failing to adhere to the requirements for subrecipient monitoring, the University risks performing inadequate or inappropriate monitoring procedures and thereby increases the risk of subawards being used for unauthorized purposes. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2022-066 The University of Colorado?s Boulder campus should strengthen its internal controls over, and ensure compliance with, federal subrecipient monitoring requirements for the Research and Development Cluster grant programs by enforcing required reviews of the subrecipient checklist for completeness to ensure all of the appropriate steps are completed, including risk assessments, and by ensuring that appropriate levels of staff are assigned responsibility for the reviews. Response University of Colorado Agree Implementation Date: November 2022 Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: ? The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. ? New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. ? Use of subcontract checklist and risk assessments required and consistently done by the team.
The following findings and recommendations relating to internal control deficiencies classified as Material Weaknesses were communicated to the Department in the previous year and have not been remediated as of June 30, 2022 because the original implementation dates provided by the Department were in a subsequent fiscal year. These complete findings and recommendations can be found within the original report and the complete recommendations can be found within Section IV: Prior Audit Recommendations of this report. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote Finding 2021-060 Misreporting of Federal Expenditures for the COVID-19 ?Pandemic EBT Food Benefits and Child Care and Development Block Grant on the Exhibit K1 Each year, the Department is required to prepare an exhibit containing the Department?s federal expenditures and related reimbursements to aid the Colorado Office of the State Controller (OSC) in the preparation of the State?s Schedule of Expenditures of Federal Awards (SEFA); this exhibit is referred to as the Exhibit K1, Schedule of Federal Assistance. The Exhibit K1 should include expenditures for grants received directly from the federal government and expended by the Department (direct expenditures), as well as expenditures for federal grants passed through by the Department to other State and/or non-State agencies (subrecipient expenditures). The SEFA is to be presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) to show the State?s expenditures of federal awards during the fiscal year. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Annually, the Department prepares its Exhibit K1 by following a process documented in its program accounting manual. First, program accountants review and analyze information from CORE for the federal Assistance Listing Number (ALN)?s related to the programs they support. The program accountants complete this review using a CORE report that the Department created, pulling transaction detail level data by ALN. Once the reviews and analysis are complete, the program accountants enter the information on the Department?s Exhibit K1 template for the correlating ALN. After the exhibit is prepared, the Department?s program accounting manual requires that it goes through two levels of review for accuracy. Once these reviews are completed, the Department submits the final Exhibit K1 to the OSC. The Department is also separately required within its approved State Plan for the COVID-19 ? Pandemic EBT Food Benefits program [ALN 10.542] (P-EBT) to report its P-EBT federal expenditures to the U.S. Department of Agriculture (USDA) via the Report of Disaster Food Stamp Benefit Issuance (FNS-292-B). The Department is also required to support the financial expenditures reported on the FNS-292-B report with source data and files, which includes a P-EBT Summary report that is exported from the Colorado Benefits Management System (CBMS) and includes the number of eligible children, number of eligible households, and total amount paid in P-EBT benefits. The P-EBT summary report is then reconciled by the Department to the County Financial Management System (CFMS), where the counties? issuance of P-EBT program benefits is accumulated and reported. For Fiscal Year 2021, the Department administered more than 70 federal programs and expended approximately $2.4 billion in federal funds. The P-EBT program and Child Care and Development Block Grant (Grant) [ALN 93.575] were two of these federal programs administered by the Department during Fiscal Year 2021. The Department reported more than $292 million in federal expenditures for the P-EBT program and approximately $74 million in federal expenditures for the Grant in Fiscal Year 2021. What was the purpose of our audit work and what work was performed? The purpose of our audit work was to evaluate the Department?s internal controls over the preparation of its Exhibit K1 during Fiscal Year 2021 and to determine whether the Department correctly reported its Fiscal Year 2021 federal grant expenditures to the OSC on its Exhibit K1. The purpose of our audit work was also to evaluate the Department?s internal controls over the financial reporting to the USDA regarding the P-EBT program. As part of our audit testwork, we compared amounts reported by the Department for direct and subrecipient federal expenditures on its Fiscal Year 2021 Exhibit K1 to the underlying financial records in CORE for the Grant and P-EBT federal programs and inquired about any differences. In addition, we made inquiries of Department staff regarding its internal control processes over the Exhibit K1 preparation, including supervisory reviews. We also reviewed 4 out of 12 Fiscal Year 2021 monthly submissions to the USDA for the FNS-292-B reports and compared federal expenditure amounts reported by the Department to the underlying financial records in CORE. How were the results of the audit work measured? The OSC is required to present the State?s SEFA in accordance with the federal requirements of the Uniform Guidance to show the State?s expenditures of federal awards during the fiscal year. Federal regulations [2 CFR 200.38(b)] define a federal award as, ?The instrument setting forth the terms and conditions. The instrument is the grant agreement, cooperative agreement, other agreement for assistance?? Federal regulations [2 CFR 200.510(b)(3) and (4)] require that the SEFA must show both total federal awards expended for each individual federal program, the Assistance Listing Number, and the total amount passed through to subrecipients for each federal program. In order to prepare the SEFA, the OSC requires state departments to submit an Exhibit K1 to report expenditures, receipts, and receivables for each federal grant program administered by the Department during the fiscal year. The OSC?s exhibit instructions include guidelines for completing the Exhibit K1, including defining ?direct and indirect expenditures? as ?all monetary and non-monetary direct and indirect Federal award expenditures,? and ?pass-through expenditures? as ?the amount of all monetary and non-monetary Federal award amounts passed through to a subrecipient.? For the Department?s Grant federal program, subrecipients consist of counties, school districts, and health centers. State Fiscal Rule 1-2, Internal Controls, requires that state departments ?implement internal accounting and administrative controls that reasonably ensure that financial transactions are accurate, reliable, conform to state fiscal rules, and reflect the underlying realities of the accounting transaction (substance rather than form).? Federal regulations [7 CFR 274.4] require the Department to submit an FNS-292-B report in the format prescribed by the USDA with information detailing the P-EBT federal benefit payments. The Department is required to support the information in the report with its underlying records. The FNS-292-B report is identified as a required report within the Department?s State Plan that is approved by the USDA. What problems did the audit work identify? The Department overstated $63.5 million in P-EBT expenditures on its June 2021 FNS-292-B report to USDA that was submitted on August 30, 2021, as well as on the Department?s Exhibit K1 for Fiscal Year 2021. The Department subsequently identified that the FNS-292-B report was misstated and updated and resubmitted the report on September 28, 2021, approximately one month later. The Department, however, did not update its Exhibit K1 for Fiscal Year 2021 to correct the error, because the program staff did not notify the accounting team of the misstatement and need for Exhibit K1 correction. Based on our audit testwork, we also determined that the Department misreported $8.7 million in the Grant?s expenditures as subrecipient, rather than direct, expenditures on its Exhibit K1. Why did these problems occur? The P-EBT program staff did not notify the Department?s accounting team, who prepares the Exhibit K1, of a revision to the FNS-292-B report. The P-EBT program staff prepared the reconciliation of the CBMS summary report to the CFMS P-EBT benefits issued report and identified a variance. The variance was eventually resolved and the P-EBT program staff resubmitted the FNS-292-B report to the USDA; however P-EBT program staff did not communicate this error to the Department?s accounting team. As a result, the accounting team was unaware of the revision and, therefore, did not update the Exhibit K1 to reflect the reduction in federal expenditures. Overall, the Department did not have adequate internal controls, such as an appropriate supervisory review process or adequate communication plan, in place for Fiscal Year 2021 to ensure that the FNS-292-B report was prepared accurately, that the Exhibit K1 was completed in accordance with the instructions provided by the OSC, and that the FNS-292-B and Exhibit K1 were reviewed for accuracy and compared to the underlying data. For the Grant program error, Department staff indicated that these funds were incorrectly identified and coded as subrecipient expenditures in CORE, which caused them to be incorrectly reported as such on the Exhibit K1. When the expenditures were initially posted in CORE, they were not adequately reviewed to determine if they were subrecipient or direct expenditures. Why do these problems matter? By failing to properly report grant expenditures to the federal government and the OSC, who ultimately then fails to properly report expenditures to the federal government on the State?s SEFA, the Department is out of compliance with federal and state reporting requirements and risks federal sanctions. In addition, because the error resulted in the Department misstating its federal expenditure results for the fiscal year, federal staff and taxpayers have an incorrect or unreliable picture of the P-EBT grant?s overall status. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2021-060 The Department of Human Services (Department) should strengthen its internal controls over the preparation of federal reports and the Exhibit K1, Schedule of Federal Assistance, by: A. Strengthening its internal controls over its monthly Pandemic Electronic Benefit Transfer Food Benefits (P-EBT) reporting to ensure its reporting is accurate and goes through supervisory review. B. Improving communication between program and accounting staff to ensure the Exhibit K1 is accurately updated when errors in federal reporting are identified and resolved. C. Improving the supervisory review process over the Exhibit K1 and the federal expenditures entered in the Colorado Operations Resource Engine (CORE), the state?s accounting system, to ensure expenditures are coded correctly as direct or subrecipient expenditures and that, ultimately, the Exhibit K1 is accurate and complete. Response Department of Human Services A. Agree Implementation Date: July 2022 CDHS agrees to enhance internal controls over monthly P-EBT reporting to better ensure accuracy. P-EBT is a new program derived from pandemic funding. Being a new program with a lack of federal guidance at implementation, and urgency to get the funds disbursed program staff had to learn about the nuances of the program and the reporting requirements as it was being implemented. During implementation we recognized that there are some inherent differences with P-EBT from other benefit programs which caused processes to have to be adjusted slightly. Additionally, timing of federal report filing for the P-EBT program is not in synch with our other processes and associated federal reporting requirements and deadlines. This makes it impossible to ensure reconciliation procedures are performed before filing occurs, which is one of our typical internal controls. As a compensating internal control CDHS will ensure that supervisory review processes are performed over P-EBT reporting, and that P-EBT reporting is reconciled to other sources (CBMS and CFMS) as soon as possible after reporting is available. If changes are discovered CDHS will make adjustments to filed P-EBT reports as needed based on reconciliation findings, and communicate changes to necessary parties. B. Agree Implementation Date: July 2022 CDHS will work to ensure better coordination between program activities and the accounting section relating to federal reporting changes. Accounting will iterate the importance of timely informing the accounting staff when changes are made to program filed federal reports. This message will be delivered in periodic fiscal meetings and identified on the closing calendar. The P-EBT program will ensure that corrections are communicated to accounting on any updates completed on the FNS-292-B report upon discovery, and no later than 30 days after the reporting period. C. Agree Implementation Date: July 2022 CDHS will ensure that review and approval processes are occurring as designed at various points in the process leading up to entry into CORE. As part of the Requisition (RQS) approval process program and accounting staff independently approve that the correct direct or subrecipient object code is used. These approved RQS transactions are then transitioned into encumbrance documents that drive which object code future expenditures will be booked to. For CCDF transactions related to this finding, both the OEC and Accounting teams inadvertently approved an incorrect object code in 4 RQS's. Staffing shortages coupled with a large increase in workload related to pandemic funding contributed to this oversight. To correct OEC and Accounting will train new staff, periodically familiarize themselves with the appropriate object codes, and perform quality assurance review over object codes before applying approval in CORE. The K1 is compiled from balances derived from expenditure data recorded in CORE. The compilation of the K1 relies on the fact that expenditure balances are accurate, and that prior reviews and approvals of individual transactions have occurred as designed. The K1 currently goes through various levels of review focusing on balance level validation coupled with analytical procedures. To enhance the review process, CDHS will ensure analytical procedures include line level expenditure comparison at the direct and subrecipient levels.