2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
2022-002 The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Assistance Listing Number and Title: Various, Research and Development Cluster ? University of Washington Federal Grantor Name: Various Federal Award/Contract Number: Various Pass-through Entity Name: Various Pass-through Award/Contract Number: Various Applicable Compliance Component: Special Tests and Provisions: Key Personnel Known Questioned Cost Amount: None Background The federal government sponsors research and development (R&D) activities under a variety of types of awards. Most commonly, these are 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 widely. Grants for R&D are awarded to non-federal entities on the basis of applications or proposals submitted to federal agencies or pass-through entities. An award is then negotiated that will include the purpose of the project, the amount of the award and the terms and conditions. R&D awards may include staffing proposals that specify key personnel who will work on the project, as well as the extent of their planned involvement. One of these key personnel is typically a principal investigator (PI) who contributes to the scientific development or execution of a project in a substantive, measurable way. The non-federal entity is required to meet key personnel commitments specified in the award and may be required to obtain approval from the grantor for certain types of changes. The University of Washington (University) is the largest recipient of federal R&D awards in the state of Washington. The University expended funds from 2,396 separate awards for the R&D grants, with expenditures totaling approximately $1.02 billion of the almost $1.17 billion expended statewide during the audit period. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. To determine if the University complied with key personnel requirements, we reviewed the University?s internal controls over monitoring key personnel time and effort and also examined grant awards to determine if key personnel identified in the application/proposal and award were involved in the project as required. We used a statistical sampling method to randomly select and examine 59 unique budget numbers assigned to R&D programs out of a total population of 7,486. We examined these samples and found: ? Four instances where we could not determine whether the University properly monitored key personnel time and effort to ensure that they met award requirements identified in the grant application/proposal and award were involved in the project as required. ? Two instances where key personnel were not involved in the project as required. Specifically, we found: o One award for which the PI was required to spend approximately 16 percent of their time on the award, but spent less than 5 percent o One award where the PI was required to spend 2 percent of their time on the award, but only spent .67 percent We consider these internal control deficiencies to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition While we determined the University had policies and procedures to ensure that key personnel are involved in the grant projects as required, there were not policies or procedures to ensure that there was sufficient University level oversight to ensure key personnel commitments were met. Effect of Condition By not establishing adequate internal controls, the University cannot reasonably ensure it meets the key personnel requirement. Recommendation We recommend the University improve its internal controls to ensure key personnel identified in the application/proposal and award were involved in the project as required. In addition, if the University identifies key personnel commitments are not going to meet required levels, ensure that federal awarding agency approval is obtained when required. University?s Response The University has established internal controls to ensure compliance with program requirements through the effort certification and project reporting processes, and budget reconciliation requirements. However, we agree there are areas for improvement int terms of staff and PI training, and available resources to monitor contribution and documentation of committed levels of effort. The University will implement the following improvements: ? The University offers multiple training courses to research administrators and principal investigators on management of sponsored awards. We will update our training materials and provide additional training on documentation of effort for PIs and key personnel, and prior approval requirements for reductions in effort. ? Update guidance and instructions for effort certifications to ensure all devoted effort is properly accounted for during the effort certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed effort for PIs and key personnel. Auditor?s Remarks We thank the University for its cooperation and assistance throughout the audit. We will review the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 308, Revision of budget and program plans, states in part: (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non-Federal share (see definition for Federal share in ? 200.1) or only the Federal share, depending upon Federal awarding agency requirements. The budget and program plans include considerations for performance and program evaluation purposes whenever required in accordance with the terms and conditions of the award. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section. (c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). (2) Change in a key person specified in the application or the Federal award. (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.