Finding 2022-004: AllowabilityFederal ProgramResearch and Development Cluster (R&D) (AL No.: Various)Federal AgenciesAgencies included within the R&D clusterFederal Award NumberAward numbers: P20GM104316, 1935956Federal Award YearJuly 1, 2021 through June 30, 2022Criteria or RequirementThe cost principles in 2 CFR Part 200, Subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:a. States, local governments, and Indian tribesb. Institutions of higher education (IHEs)c. Nonprofit organizationsAs provided in 2 CFR section 200.101, the cost principles requirements apply to all federal awards with the exception of grant agreements and cooperative agreements providing food commodities; agreements for loans, loan guarantees, interest subsidies, insurance; and programs listed in 2 CFR section 200.101(d) (see Appendix I of this Supplement). Federal awards administered by publicly owned hospitals and other providers of medical care are exempt from 2 CFR Part 200, Subpart E, but are subject to the requirements 45 CFR Part 75, Appendix IX, the Department of Health and Human Services (HHS) implementation of 2 CFR Part 200. The cost principles applicable to a non-federal entity apply to all federal awards received by the entity, regardless of whether the awards are received directly from the federal awarding agency or indirectly through a pass-through entity. For this purpose, federal awards include cost-reimbursement contracts under the Federal Acquisition Regulation (FAR). The cost principles do not apply to federal awards under which a non-federal entity is not required to account to the federal awarding agency or pass-through entity for actual costs incurred.The requirements for allowable costs/cost principles are contained in 2 CFR Part 200, Subpart E, program legislation, federal awarding agency regulations, and the terms and conditions of the award.Basic GuidelinesExcept where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;1. Be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E.2. Conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E or in the federal award as to types or amount of cost items.3. Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity.4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.5. Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only as otherwise provided for in 2 CFR Part 200.6. Not be included as a cost or used to meet cost-sharing or matching requirements of any other federally financed program in either the current or a prior period.7. Be adequately documented.Per 2 CFR Section 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.Condition Found, including PerspectiveIn our testing over allowability of cost, we identified one transaction in a sample of 40 non-payroll transactions for which the University paid and allocated the cost, however, the service contract period had not yet started. In addition, we identified a second transaction for an intergovernmental personnel agreement (in the same sample of 40 non-payroll transactions) which included an advance on future service.Possible Cause and EffectThe University?s internal control over compliance with allowability and allocability was not operating at a level of precision (period of service) consistently through fiscal year 2022.Questioned CostsKnown questioned costs aggregated $52,445 (direct cost + an allocation of indirect costs).Statistical ValidityThe sample was not intended to be, and was not, a statistically valid sample.Repeat Finding in the Prior YearNoRecommendationWe recommend the University enhance the level of precision around its internal control over compliance related to the timing of allocating and charges costs.Views of Responsible OfficialsThe University agrees with this finding. The questioned costs will be removed from the grant charged. Additionally, the University will provide additional education and awareness over the billing of federal awards to ensure that expenses relate to the period being billed and services being performed.
Finding 2022-004: AllowabilityFederal ProgramResearch and Development Cluster (R&D) (AL No.: Various)Federal AgenciesAgencies included within the R&D clusterFederal Award NumberAward numbers: P20GM104316, 1935956Federal Award YearJuly 1, 2021 through June 30, 2022Criteria or RequirementThe cost principles in 2 CFR Part 200, Subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:a. States, local governments, and Indian tribesb. Institutions of higher education (IHEs)c. Nonprofit organizationsAs provided in 2 CFR section 200.101, the cost principles requirements apply to all federal awards with the exception of grant agreements and cooperative agreements providing food commodities; agreements for loans, loan guarantees, interest subsidies, insurance; and programs listed in 2 CFR section 200.101(d) (see Appendix I of this Supplement). Federal awards administered by publicly owned hospitals and other providers of medical care are exempt from 2 CFR Part 200, Subpart E, but are subject to the requirements 45 CFR Part 75, Appendix IX, the Department of Health and Human Services (HHS) implementation of 2 CFR Part 200. The cost principles applicable to a non-federal entity apply to all federal awards received by the entity, regardless of whether the awards are received directly from the federal awarding agency or indirectly through a pass-through entity. For this purpose, federal awards include cost-reimbursement contracts under the Federal Acquisition Regulation (FAR). The cost principles do not apply to federal awards under which a non-federal entity is not required to account to the federal awarding agency or pass-through entity for actual costs incurred.The requirements for allowable costs/cost principles are contained in 2 CFR Part 200, Subpart E, program legislation, federal awarding agency regulations, and the terms and conditions of the award.Basic GuidelinesExcept where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;1. Be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E.2. Conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E or in the federal award as to types or amount of cost items.3. Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity.4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.5. Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only as otherwise provided for in 2 CFR Part 200.6. Not be included as a cost or used to meet cost-sharing or matching requirements of any other federally financed program in either the current or a prior period.7. Be adequately documented.Per 2 CFR Section 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.Condition Found, including PerspectiveIn our testing over allowability of cost, we identified one transaction in a sample of 40 non-payroll transactions for which the University paid and allocated the cost, however, the service contract period had not yet started. In addition, we identified a second transaction for an intergovernmental personnel agreement (in the same sample of 40 non-payroll transactions) which included an advance on future service.Possible Cause and EffectThe University?s internal control over compliance with allowability and allocability was not operating at a level of precision (period of service) consistently through fiscal year 2022.Questioned CostsKnown questioned costs aggregated $52,445 (direct cost + an allocation of indirect costs).Statistical ValidityThe sample was not intended to be, and was not, a statistically valid sample.Repeat Finding in the Prior YearNoRecommendationWe recommend the University enhance the level of precision around its internal control over compliance related to the timing of allocating and charges costs.Views of Responsible OfficialsThe University agrees with this finding. The questioned costs will be removed from the grant charged. Additionally, the University will provide additional education and awareness over the billing of federal awards to ensure that expenses relate to the period being billed and services being performed.
Finding 2022-004: AllowabilityFederal ProgramResearch and Development Cluster (R&D) (AL No.: Various)Federal AgenciesAgencies included within the R&D clusterFederal Award NumberAward numbers: P20GM104316, 1935956Federal Award YearJuly 1, 2021 through June 30, 2022Criteria or RequirementThe cost principles in 2 CFR Part 200, Subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:a. States, local governments, and Indian tribesb. Institutions of higher education (IHEs)c. Nonprofit organizationsAs provided in 2 CFR section 200.101, the cost principles requirements apply to all federal awards with the exception of grant agreements and cooperative agreements providing food commodities; agreements for loans, loan guarantees, interest subsidies, insurance; and programs listed in 2 CFR section 200.101(d) (see Appendix I of this Supplement). Federal awards administered by publicly owned hospitals and other providers of medical care are exempt from 2 CFR Part 200, Subpart E, but are subject to the requirements 45 CFR Part 75, Appendix IX, the Department of Health and Human Services (HHS) implementation of 2 CFR Part 200. The cost principles applicable to a non-federal entity apply to all federal awards received by the entity, regardless of whether the awards are received directly from the federal awarding agency or indirectly through a pass-through entity. For this purpose, federal awards include cost-reimbursement contracts under the Federal Acquisition Regulation (FAR). The cost principles do not apply to federal awards under which a non-federal entity is not required to account to the federal awarding agency or pass-through entity for actual costs incurred.The requirements for allowable costs/cost principles are contained in 2 CFR Part 200, Subpart E, program legislation, federal awarding agency regulations, and the terms and conditions of the award.Basic GuidelinesExcept where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;1. Be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E.2. Conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E or in the federal award as to types or amount of cost items.3. Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity.4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.5. Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only as otherwise provided for in 2 CFR Part 200.6. Not be included as a cost or used to meet cost-sharing or matching requirements of any other federally financed program in either the current or a prior period.7. Be adequately documented.Per 2 CFR Section 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.Condition Found, including PerspectiveIn our testing over allowability of cost, we identified one transaction in a sample of 40 non-payroll transactions for which the University paid and allocated the cost, however, the service contract period had not yet started. In addition, we identified a second transaction for an intergovernmental personnel agreement (in the same sample of 40 non-payroll transactions) which included an advance on future service.Possible Cause and EffectThe University?s internal control over compliance with allowability and allocability was not operating at a level of precision (period of service) consistently through fiscal year 2022.Questioned CostsKnown questioned costs aggregated $52,445 (direct cost + an allocation of indirect costs).Statistical ValidityThe sample was not intended to be, and was not, a statistically valid sample.Repeat Finding in the Prior YearNoRecommendationWe recommend the University enhance the level of precision around its internal control over compliance related to the timing of allocating and charges costs.Views of Responsible OfficialsThe University agrees with this finding. The questioned costs will be removed from the grant charged. Additionally, the University will provide additional education and awareness over the billing of federal awards to ensure that expenses relate to the period being billed and services being performed.
Finding 2022-004: AllowabilityFederal ProgramResearch and Development Cluster (R&D) (AL No.: Various)Federal AgenciesAgencies included within the R&D clusterFederal Award NumberAward numbers: P20GM104316, 1935956Federal Award YearJuly 1, 2021 through June 30, 2022Criteria or RequirementThe cost principles in 2 CFR Part 200, Subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:a. States, local governments, and Indian tribesb. Institutions of higher education (IHEs)c. Nonprofit organizationsAs provided in 2 CFR section 200.101, the cost principles requirements apply to all federal awards with the exception of grant agreements and cooperative agreements providing food commodities; agreements for loans, loan guarantees, interest subsidies, insurance; and programs listed in 2 CFR section 200.101(d) (see Appendix I of this Supplement). Federal awards administered by publicly owned hospitals and other providers of medical care are exempt from 2 CFR Part 200, Subpart E, but are subject to the requirements 45 CFR Part 75, Appendix IX, the Department of Health and Human Services (HHS) implementation of 2 CFR Part 200. The cost principles applicable to a non-federal entity apply to all federal awards received by the entity, regardless of whether the awards are received directly from the federal awarding agency or indirectly through a pass-through entity. For this purpose, federal awards include cost-reimbursement contracts under the Federal Acquisition Regulation (FAR). The cost principles do not apply to federal awards under which a non-federal entity is not required to account to the federal awarding agency or pass-through entity for actual costs incurred.The requirements for allowable costs/cost principles are contained in 2 CFR Part 200, Subpart E, program legislation, federal awarding agency regulations, and the terms and conditions of the award.Basic GuidelinesExcept where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;1. Be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E.2. Conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E or in the federal award as to types or amount of cost items.3. Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity.4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.5. Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only as otherwise provided for in 2 CFR Part 200.6. Not be included as a cost or used to meet cost-sharing or matching requirements of any other federally financed program in either the current or a prior period.7. Be adequately documented.Per 2 CFR Section 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.Condition Found, including PerspectiveIn our testing over allowability of cost, we identified one transaction in a sample of 40 non-payroll transactions for which the University paid and allocated the cost, however, the service contract period had not yet started. In addition, we identified a second transaction for an intergovernmental personnel agreement (in the same sample of 40 non-payroll transactions) which included an advance on future service.Possible Cause and EffectThe University?s internal control over compliance with allowability and allocability was not operating at a level of precision (period of service) consistently through fiscal year 2022.Questioned CostsKnown questioned costs aggregated $52,445 (direct cost + an allocation of indirect costs).Statistical ValidityThe sample was not intended to be, and was not, a statistically valid sample.Repeat Finding in the Prior YearNoRecommendationWe recommend the University enhance the level of precision around its internal control over compliance related to the timing of allocating and charges costs.Views of Responsible OfficialsThe University agrees with this finding. The questioned costs will be removed from the grant charged. Additionally, the University will provide additional education and awareness over the billing of federal awards to ensure that expenses relate to the period being billed and services being performed.
Finding 2022-004: AllowabilityFederal ProgramResearch and Development Cluster (R&D) (AL No.: Various)Federal AgenciesAgencies included within the R&D clusterFederal Award NumberAward numbers: P20GM104316, 1935956Federal Award YearJuly 1, 2021 through June 30, 2022Criteria or RequirementThe cost principles in 2 CFR Part 200, Subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:a. States, local governments, and Indian tribesb. Institutions of higher education (IHEs)c. Nonprofit organizationsAs provided in 2 CFR section 200.101, the cost principles requirements apply to all federal awards with the exception of grant agreements and cooperative agreements providing food commodities; agreements for loans, loan guarantees, interest subsidies, insurance; and programs listed in 2 CFR section 200.101(d) (see Appendix I of this Supplement). Federal awards administered by publicly owned hospitals and other providers of medical care are exempt from 2 CFR Part 200, Subpart E, but are subject to the requirements 45 CFR Part 75, Appendix IX, the Department of Health and Human Services (HHS) implementation of 2 CFR Part 200. The cost principles applicable to a non-federal entity apply to all federal awards received by the entity, regardless of whether the awards are received directly from the federal awarding agency or indirectly through a pass-through entity. For this purpose, federal awards include cost-reimbursement contracts under the Federal Acquisition Regulation (FAR). The cost principles do not apply to federal awards under which a non-federal entity is not required to account to the federal awarding agency or pass-through entity for actual costs incurred.The requirements for allowable costs/cost principles are contained in 2 CFR Part 200, Subpart E, program legislation, federal awarding agency regulations, and the terms and conditions of the award.Basic GuidelinesExcept where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;1. Be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E.2. Conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E or in the federal award as to types or amount of cost items.3. Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity.4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.5. Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only as otherwise provided for in 2 CFR Part 200.6. Not be included as a cost or used to meet cost-sharing or matching requirements of any other federally financed program in either the current or a prior period.7. Be adequately documented.Per 2 CFR Section 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.Condition Found, including PerspectiveIn our testing over allowability of cost, we identified one transaction in a sample of 40 non-payroll transactions for which the University paid and allocated the cost, however, the service contract period had not yet started. In addition, we identified a second transaction for an intergovernmental personnel agreement (in the same sample of 40 non-payroll transactions) which included an advance on future service.Possible Cause and EffectThe University?s internal control over compliance with allowability and allocability was not operating at a level of precision (period of service) consistently through fiscal year 2022.Questioned CostsKnown questioned costs aggregated $52,445 (direct cost + an allocation of indirect costs).Statistical ValidityThe sample was not intended to be, and was not, a statistically valid sample.Repeat Finding in the Prior YearNoRecommendationWe recommend the University enhance the level of precision around its internal control over compliance related to the timing of allocating and charges costs.Views of Responsible OfficialsThe University agrees with this finding. The questioned costs will be removed from the grant charged. Additionally, the University will provide additional education and awareness over the billing of federal awards to ensure that expenses relate to the period being billed and services being performed.
Finding 2022-004: AllowabilityFederal ProgramResearch and Development Cluster (R&D) (AL No.: Various)Federal AgenciesAgencies included within the R&D clusterFederal Award NumberAward numbers: P20GM104316, 1935956Federal Award YearJuly 1, 2021 through June 30, 2022Criteria or RequirementThe cost principles in 2 CFR Part 200, Subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:a. States, local governments, and Indian tribesb. Institutions of higher education (IHEs)c. Nonprofit organizationsAs provided in 2 CFR section 200.101, the cost principles requirements apply to all federal awards with the exception of grant agreements and cooperative agreements providing food commodities; agreements for loans, loan guarantees, interest subsidies, insurance; and programs listed in 2 CFR section 200.101(d) (see Appendix I of this Supplement). Federal awards administered by publicly owned hospitals and other providers of medical care are exempt from 2 CFR Part 200, Subpart E, but are subject to the requirements 45 CFR Part 75, Appendix IX, the Department of Health and Human Services (HHS) implementation of 2 CFR Part 200. The cost principles applicable to a non-federal entity apply to all federal awards received by the entity, regardless of whether the awards are received directly from the federal awarding agency or indirectly through a pass-through entity. For this purpose, federal awards include cost-reimbursement contracts under the Federal Acquisition Regulation (FAR). The cost principles do not apply to federal awards under which a non-federal entity is not required to account to the federal awarding agency or pass-through entity for actual costs incurred.The requirements for allowable costs/cost principles are contained in 2 CFR Part 200, Subpart E, program legislation, federal awarding agency regulations, and the terms and conditions of the award.Basic GuidelinesExcept where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;1. Be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E.2. Conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E or in the federal award as to types or amount of cost items.3. Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity.4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.5. Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only as otherwise provided for in 2 CFR Part 200.6. Not be included as a cost or used to meet cost-sharing or matching requirements of any other federally financed program in either the current or a prior period.7. Be adequately documented.Per 2 CFR Section 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.Condition Found, including PerspectiveIn our testing over allowability of cost, we identified one transaction in a sample of 40 non-payroll transactions for which the University paid and allocated the cost, however, the service contract period had not yet started. In addition, we identified a second transaction for an intergovernmental personnel agreement (in the same sample of 40 non-payroll transactions) which included an advance on future service.Possible Cause and EffectThe University?s internal control over compliance with allowability and allocability was not operating at a level of precision (period of service) consistently through fiscal year 2022.Questioned CostsKnown questioned costs aggregated $52,445 (direct cost + an allocation of indirect costs).Statistical ValidityThe sample was not intended to be, and was not, a statistically valid sample.Repeat Finding in the Prior YearNoRecommendationWe recommend the University enhance the level of precision around its internal control over compliance related to the timing of allocating and charges costs.Views of Responsible OfficialsThe University agrees with this finding. The questioned costs will be removed from the grant charged. Additionally, the University will provide additional education and awareness over the billing of federal awards to ensure that expenses relate to the period being billed and services being performed.
Finding 2022-004: AllowabilityFederal ProgramResearch and Development Cluster (R&D) (AL No.: Various)Federal AgenciesAgencies included within the R&D clusterFederal Award NumberAward numbers: P20GM104316, 1935956Federal Award YearJuly 1, 2021 through June 30, 2022Criteria or RequirementThe cost principles in 2 CFR Part 200, Subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:a. States, local governments, and Indian tribesb. Institutions of higher education (IHEs)c. Nonprofit organizationsAs provided in 2 CFR section 200.101, the cost principles requirements apply to all federal awards with the exception of grant agreements and cooperative agreements providing food commodities; agreements for loans, loan guarantees, interest subsidies, insurance; and programs listed in 2 CFR section 200.101(d) (see Appendix I of this Supplement). Federal awards administered by publicly owned hospitals and other providers of medical care are exempt from 2 CFR Part 200, Subpart E, but are subject to the requirements 45 CFR Part 75, Appendix IX, the Department of Health and Human Services (HHS) implementation of 2 CFR Part 200. The cost principles applicable to a non-federal entity apply to all federal awards received by the entity, regardless of whether the awards are received directly from the federal awarding agency or indirectly through a pass-through entity. For this purpose, federal awards include cost-reimbursement contracts under the Federal Acquisition Regulation (FAR). The cost principles do not apply to federal awards under which a non-federal entity is not required to account to the federal awarding agency or pass-through entity for actual costs incurred.The requirements for allowable costs/cost principles are contained in 2 CFR Part 200, Subpart E, program legislation, federal awarding agency regulations, and the terms and conditions of the award.Basic GuidelinesExcept where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;1. Be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E.2. Conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E or in the federal award as to types or amount of cost items.3. Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity.4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.5. Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only as otherwise provided for in 2 CFR Part 200.6. Not be included as a cost or used to meet cost-sharing or matching requirements of any other federally financed program in either the current or a prior period.7. Be adequately documented.Per 2 CFR Section 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.Condition Found, including PerspectiveIn our testing over allowability of cost, we identified one transaction in a sample of 40 non-payroll transactions for which the University paid and allocated the cost, however, the service contract period had not yet started. In addition, we identified a second transaction for an intergovernmental personnel agreement (in the same sample of 40 non-payroll transactions) which included an advance on future service.Possible Cause and EffectThe University?s internal control over compliance with allowability and allocability was not operating at a level of precision (period of service) consistently through fiscal year 2022.Questioned CostsKnown questioned costs aggregated $52,445 (direct cost + an allocation of indirect costs).Statistical ValidityThe sample was not intended to be, and was not, a statistically valid sample.Repeat Finding in the Prior YearNoRecommendationWe recommend the University enhance the level of precision around its internal control over compliance related to the timing of allocating and charges costs.Views of Responsible OfficialsThe University agrees with this finding. The questioned costs will be removed from the grant charged. Additionally, the University will provide additional education and awareness over the billing of federal awards to ensure that expenses relate to the period being billed and services being performed.
Finding 2022-004: AllowabilityFederal ProgramResearch and Development Cluster (R&D) (AL No.: Various)Federal AgenciesAgencies included within the R&D clusterFederal Award NumberAward numbers: P20GM104316, 1935956Federal Award YearJuly 1, 2021 through June 30, 2022Criteria or RequirementThe cost principles in 2 CFR Part 200, Subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:a. States, local governments, and Indian tribesb. Institutions of higher education (IHEs)c. Nonprofit organizationsAs provided in 2 CFR section 200.101, the cost principles requirements apply to all federal awards with the exception of grant agreements and cooperative agreements providing food commodities; agreements for loans, loan guarantees, interest subsidies, insurance; and programs listed in 2 CFR section 200.101(d) (see Appendix I of this Supplement). Federal awards administered by publicly owned hospitals and other providers of medical care are exempt from 2 CFR Part 200, Subpart E, but are subject to the requirements 45 CFR Part 75, Appendix IX, the Department of Health and Human Services (HHS) implementation of 2 CFR Part 200. The cost principles applicable to a non-federal entity apply to all federal awards received by the entity, regardless of whether the awards are received directly from the federal awarding agency or indirectly through a pass-through entity. For this purpose, federal awards include cost-reimbursement contracts under the Federal Acquisition Regulation (FAR). The cost principles do not apply to federal awards under which a non-federal entity is not required to account to the federal awarding agency or pass-through entity for actual costs incurred.The requirements for allowable costs/cost principles are contained in 2 CFR Part 200, Subpart E, program legislation, federal awarding agency regulations, and the terms and conditions of the award.Basic GuidelinesExcept where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;1. Be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E.2. Conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E or in the federal award as to types or amount of cost items.3. Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity.4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.5. Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only as otherwise provided for in 2 CFR Part 200.6. Not be included as a cost or used to meet cost-sharing or matching requirements of any other federally financed program in either the current or a prior period.7. Be adequately documented.Per 2 CFR Section 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.Condition Found, including PerspectiveIn our testing over allowability of cost, we identified one transaction in a sample of 40 non-payroll transactions for which the University paid and allocated the cost, however, the service contract period had not yet started. In addition, we identified a second transaction for an intergovernmental personnel agreement (in the same sample of 40 non-payroll transactions) which included an advance on future service.Possible Cause and EffectThe University?s internal control over compliance with allowability and allocability was not operating at a level of precision (period of service) consistently through fiscal year 2022.Questioned CostsKnown questioned costs aggregated $52,445 (direct cost + an allocation of indirect costs).Statistical ValidityThe sample was not intended to be, and was not, a statistically valid sample.Repeat Finding in the Prior YearNoRecommendationWe recommend the University enhance the level of precision around its internal control over compliance related to the timing of allocating and charges costs.Views of Responsible OfficialsThe University agrees with this finding. The questioned costs will be removed from the grant charged. Additionally, the University will provide additional education and awareness over the billing of federal awards to ensure that expenses relate to the period being billed and services being performed.
Finding 2022-004: AllowabilityFederal ProgramResearch and Development Cluster (R&D) (AL No.: Various)Federal AgenciesAgencies included within the R&D clusterFederal Award NumberAward numbers: P20GM104316, 1935956Federal Award YearJuly 1, 2021 through June 30, 2022Criteria or RequirementThe cost principles in 2 CFR Part 200, Subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:a. States, local governments, and Indian tribesb. Institutions of higher education (IHEs)c. Nonprofit organizationsAs provided in 2 CFR section 200.101, the cost principles requirements apply to all federal awards with the exception of grant agreements and cooperative agreements providing food commodities; agreements for loans, loan guarantees, interest subsidies, insurance; and programs listed in 2 CFR section 200.101(d) (see Appendix I of this Supplement). Federal awards administered by publicly owned hospitals and other providers of medical care are exempt from 2 CFR Part 200, Subpart E, but are subject to the requirements 45 CFR Part 75, Appendix IX, the Department of Health and Human Services (HHS) implementation of 2 CFR Part 200. The cost principles applicable to a non-federal entity apply to all federal awards received by the entity, regardless of whether the awards are received directly from the federal awarding agency or indirectly through a pass-through entity. For this purpose, federal awards include cost-reimbursement contracts under the Federal Acquisition Regulation (FAR). The cost principles do not apply to federal awards under which a non-federal entity is not required to account to the federal awarding agency or pass-through entity for actual costs incurred.The requirements for allowable costs/cost principles are contained in 2 CFR Part 200, Subpart E, program legislation, federal awarding agency regulations, and the terms and conditions of the award.Basic GuidelinesExcept where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;1. Be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E.2. Conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E or in the federal award as to types or amount of cost items.3. Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity.4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.5. Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only as otherwise provided for in 2 CFR Part 200.6. Not be included as a cost or used to meet cost-sharing or matching requirements of any other federally financed program in either the current or a prior period.7. Be adequately documented.Per 2 CFR Section 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.Condition Found, including PerspectiveIn our testing over allowability of cost, we identified one transaction in a sample of 40 non-payroll transactions for which the University paid and allocated the cost, however, the service contract period had not yet started. In addition, we identified a second transaction for an intergovernmental personnel agreement (in the same sample of 40 non-payroll transactions) which included an advance on future service.Possible Cause and EffectThe University?s internal control over compliance with allowability and allocability was not operating at a level of precision (period of service) consistently through fiscal year 2022.Questioned CostsKnown questioned costs aggregated $52,445 (direct cost + an allocation of indirect costs).Statistical ValidityThe sample was not intended to be, and was not, a statistically valid sample.Repeat Finding in the Prior YearNoRecommendationWe recommend the University enhance the level of precision around its internal control over compliance related to the timing of allocating and charges costs.Views of Responsible OfficialsThe University agrees with this finding. The questioned costs will be removed from the grant charged. Additionally, the University will provide additional education and awareness over the billing of federal awards to ensure that expenses relate to the period being billed and services being performed.
Finding 2022-004: AllowabilityFederal ProgramResearch and Development Cluster (R&D) (AL No.: Various)Federal AgenciesAgencies included within the R&D clusterFederal Award NumberAward numbers: P20GM104316, 1935956Federal Award YearJuly 1, 2021 through June 30, 2022Criteria or RequirementThe cost principles in 2 CFR Part 200, Subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:a. States, local governments, and Indian tribesb. Institutions of higher education (IHEs)c. Nonprofit organizationsAs provided in 2 CFR section 200.101, the cost principles requirements apply to all federal awards with the exception of grant agreements and cooperative agreements providing food commodities; agreements for loans, loan guarantees, interest subsidies, insurance; and programs listed in 2 CFR section 200.101(d) (see Appendix I of this Supplement). Federal awards administered by publicly owned hospitals and other providers of medical care are exempt from 2 CFR Part 200, Subpart E, but are subject to the requirements 45 CFR Part 75, Appendix IX, the Department of Health and Human Services (HHS) implementation of 2 CFR Part 200. The cost principles applicable to a non-federal entity apply to all federal awards received by the entity, regardless of whether the awards are received directly from the federal awarding agency or indirectly through a pass-through entity. For this purpose, federal awards include cost-reimbursement contracts under the Federal Acquisition Regulation (FAR). The cost principles do not apply to federal awards under which a non-federal entity is not required to account to the federal awarding agency or pass-through entity for actual costs incurred.The requirements for allowable costs/cost principles are contained in 2 CFR Part 200, Subpart E, program legislation, federal awarding agency regulations, and the terms and conditions of the award.Basic GuidelinesExcept where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;1. Be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E.2. Conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E or in the federal award as to types or amount of cost items.3. Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity.4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.5. Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only as otherwise provided for in 2 CFR Part 200.6. Not be included as a cost or used to meet cost-sharing or matching requirements of any other federally financed program in either the current or a prior period.7. Be adequately documented.Per 2 CFR Section 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.Condition Found, including PerspectiveIn our testing over allowability of cost, we identified one transaction in a sample of 40 non-payroll transactions for which the University paid and allocated the cost, however, the service contract period had not yet started. In addition, we identified a second transaction for an intergovernmental personnel agreement (in the same sample of 40 non-payroll transactions) which included an advance on future service.Possible Cause and EffectThe University?s internal control over compliance with allowability and allocability was not operating at a level of precision (period of service) consistently through fiscal year 2022.Questioned CostsKnown questioned costs aggregated $52,445 (direct cost + an allocation of indirect costs).Statistical ValidityThe sample was not intended to be, and was not, a statistically valid sample.Repeat Finding in the Prior YearNoRecommendationWe recommend the University enhance the level of precision around its internal control over compliance related to the timing of allocating and charges costs.Views of Responsible OfficialsThe University agrees with this finding. The questioned costs will be removed from the grant charged. Additionally, the University will provide additional education and awareness over the billing of federal awards to ensure that expenses relate to the period being billed and services being performed.
Finding 2022-004: AllowabilityFederal ProgramResearch and Development Cluster (R&D) (AL No.: Various)Federal AgenciesAgencies included within the R&D clusterFederal Award NumberAward numbers: P20GM104316, 1935956Federal Award YearJuly 1, 2021 through June 30, 2022Criteria or RequirementThe cost principles in 2 CFR Part 200, Subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:a. States, local governments, and Indian tribesb. Institutions of higher education (IHEs)c. Nonprofit organizationsAs provided in 2 CFR section 200.101, the cost principles requirements apply to all federal awards with the exception of grant agreements and cooperative agreements providing food commodities; agreements for loans, loan guarantees, interest subsidies, insurance; and programs listed in 2 CFR section 200.101(d) (see Appendix I of this Supplement). Federal awards administered by publicly owned hospitals and other providers of medical care are exempt from 2 CFR Part 200, Subpart E, but are subject to the requirements 45 CFR Part 75, Appendix IX, the Department of Health and Human Services (HHS) implementation of 2 CFR Part 200. The cost principles applicable to a non-federal entity apply to all federal awards received by the entity, regardless of whether the awards are received directly from the federal awarding agency or indirectly through a pass-through entity. For this purpose, federal awards include cost-reimbursement contracts under the Federal Acquisition Regulation (FAR). The cost principles do not apply to federal awards under which a non-federal entity is not required to account to the federal awarding agency or pass-through entity for actual costs incurred.The requirements for allowable costs/cost principles are contained in 2 CFR Part 200, Subpart E, program legislation, federal awarding agency regulations, and the terms and conditions of the award.Basic GuidelinesExcept where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;1. Be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E.2. Conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E or in the federal award as to types or amount of cost items.3. Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity.4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.5. Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only as otherwise provided for in 2 CFR Part 200.6. Not be included as a cost or used to meet cost-sharing or matching requirements of any other federally financed program in either the current or a prior period.7. Be adequately documented.Per 2 CFR Section 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.Condition Found, including PerspectiveIn our testing over allowability of cost, we identified one transaction in a sample of 40 non-payroll transactions for which the University paid and allocated the cost, however, the service contract period had not yet started. In addition, we identified a second transaction for an intergovernmental personnel agreement (in the same sample of 40 non-payroll transactions) which included an advance on future service.Possible Cause and EffectThe University?s internal control over compliance with allowability and allocability was not operating at a level of precision (period of service) consistently through fiscal year 2022.Questioned CostsKnown questioned costs aggregated $52,445 (direct cost + an allocation of indirect costs).Statistical ValidityThe sample was not intended to be, and was not, a statistically valid sample.Repeat Finding in the Prior YearNoRecommendationWe recommend the University enhance the level of precision around its internal control over compliance related to the timing of allocating and charges costs.Views of Responsible OfficialsThe University agrees with this finding. The questioned costs will be removed from the grant charged. Additionally, the University will provide additional education and awareness over the billing of federal awards to ensure that expenses relate to the period being billed and services being performed.
Finding 2022-004: AllowabilityFederal ProgramResearch and Development Cluster (R&D) (AL No.: Various)Federal AgenciesAgencies included within the R&D clusterFederal Award NumberAward numbers: P20GM104316, 1935956Federal Award YearJuly 1, 2021 through June 30, 2022Criteria or RequirementThe cost principles in 2 CFR Part 200, Subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:a. States, local governments, and Indian tribesb. Institutions of higher education (IHEs)c. Nonprofit organizationsAs provided in 2 CFR section 200.101, the cost principles requirements apply to all federal awards with the exception of grant agreements and cooperative agreements providing food commodities; agreements for loans, loan guarantees, interest subsidies, insurance; and programs listed in 2 CFR section 200.101(d) (see Appendix I of this Supplement). Federal awards administered by publicly owned hospitals and other providers of medical care are exempt from 2 CFR Part 200, Subpart E, but are subject to the requirements 45 CFR Part 75, Appendix IX, the Department of Health and Human Services (HHS) implementation of 2 CFR Part 200. The cost principles applicable to a non-federal entity apply to all federal awards received by the entity, regardless of whether the awards are received directly from the federal awarding agency or indirectly through a pass-through entity. For this purpose, federal awards include cost-reimbursement contracts under the Federal Acquisition Regulation (FAR). The cost principles do not apply to federal awards under which a non-federal entity is not required to account to the federal awarding agency or pass-through entity for actual costs incurred.The requirements for allowable costs/cost principles are contained in 2 CFR Part 200, Subpart E, program legislation, federal awarding agency regulations, and the terms and conditions of the award.Basic GuidelinesExcept where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;1. Be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E.2. Conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E or in the federal award as to types or amount of cost items.3. Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity.4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.5. Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only as otherwise provided for in 2 CFR Part 200.6. Not be included as a cost or used to meet cost-sharing or matching requirements of any other federally financed program in either the current or a prior period.7. Be adequately documented.Per 2 CFR Section 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.Condition Found, including PerspectiveIn our testing over allowability of cost, we identified one transaction in a sample of 40 non-payroll transactions for which the University paid and allocated the cost, however, the service contract period had not yet started. In addition, we identified a second transaction for an intergovernmental personnel agreement (in the same sample of 40 non-payroll transactions) which included an advance on future service.Possible Cause and EffectThe University?s internal control over compliance with allowability and allocability was not operating at a level of precision (period of service) consistently through fiscal year 2022.Questioned CostsKnown questioned costs aggregated $52,445 (direct cost + an allocation of indirect costs).Statistical ValidityThe sample was not intended to be, and was not, a statistically valid sample.Repeat Finding in the Prior YearNoRecommendationWe recommend the University enhance the level of precision around its internal control over compliance related to the timing of allocating and charges costs.Views of Responsible OfficialsThe University agrees with this finding. The questioned costs will be removed from the grant charged. Additionally, the University will provide additional education and awareness over the billing of federal awards to ensure that expenses relate to the period being billed and services being performed.
Finding 2022-004: AllowabilityFederal ProgramResearch and Development Cluster (R&D) (AL No.: Various)Federal AgenciesAgencies included within the R&D clusterFederal Award NumberAward numbers: P20GM104316, 1935956Federal Award YearJuly 1, 2021 through June 30, 2022Criteria or RequirementThe cost principles in 2 CFR Part 200, Subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:a. States, local governments, and Indian tribesb. Institutions of higher education (IHEs)c. Nonprofit organizationsAs provided in 2 CFR section 200.101, the cost principles requirements apply to all federal awards with the exception of grant agreements and cooperative agreements providing food commodities; agreements for loans, loan guarantees, interest subsidies, insurance; and programs listed in 2 CFR section 200.101(d) (see Appendix I of this Supplement). Federal awards administered by publicly owned hospitals and other providers of medical care are exempt from 2 CFR Part 200, Subpart E, but are subject to the requirements 45 CFR Part 75, Appendix IX, the Department of Health and Human Services (HHS) implementation of 2 CFR Part 200. The cost principles applicable to a non-federal entity apply to all federal awards received by the entity, regardless of whether the awards are received directly from the federal awarding agency or indirectly through a pass-through entity. For this purpose, federal awards include cost-reimbursement contracts under the Federal Acquisition Regulation (FAR). The cost principles do not apply to federal awards under which a non-federal entity is not required to account to the federal awarding agency or pass-through entity for actual costs incurred.The requirements for allowable costs/cost principles are contained in 2 CFR Part 200, Subpart E, program legislation, federal awarding agency regulations, and the terms and conditions of the award.Basic GuidelinesExcept where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;1. Be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E.2. Conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E or in the federal award as to types or amount of cost items.3. Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity.4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.5. Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only as otherwise provided for in 2 CFR Part 200.6. Not be included as a cost or used to meet cost-sharing or matching requirements of any other federally financed program in either the current or a prior period.7. Be adequately documented.Per 2 CFR Section 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.Condition Found, including PerspectiveIn our testing over allowability of cost, we identified one transaction in a sample of 40 non-payroll transactions for which the University paid and allocated the cost, however, the service contract period had not yet started. In addition, we identified a second transaction for an intergovernmental personnel agreement (in the same sample of 40 non-payroll transactions) which included an advance on future service.Possible Cause and EffectThe University?s internal control over compliance with allowability and allocability was not operating at a level of precision (period of service) consistently through fiscal year 2022.Questioned CostsKnown questioned costs aggregated $52,445 (direct cost + an allocation of indirect costs).Statistical ValidityThe sample was not intended to be, and was not, a statistically valid sample.Repeat Finding in the Prior YearNoRecommendationWe recommend the University enhance the level of precision around its internal control over compliance related to the timing of allocating and charges costs.Views of Responsible OfficialsThe University agrees with this finding. The questioned costs will be removed from the grant charged. Additionally, the University will provide additional education and awareness over the billing of federal awards to ensure that expenses relate to the period being billed and services being performed.
Finding 2022-004: AllowabilityFederal ProgramResearch and Development Cluster (R&D) (AL No.: Various)Federal AgenciesAgencies included within the R&D clusterFederal Award NumberAward numbers: P20GM104316, 1935956Federal Award YearJuly 1, 2021 through June 30, 2022Criteria or RequirementThe cost principles in 2 CFR Part 200, Subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:a. States, local governments, and Indian tribesb. Institutions of higher education (IHEs)c. Nonprofit organizationsAs provided in 2 CFR section 200.101, the cost principles requirements apply to all federal awards with the exception of grant agreements and cooperative agreements providing food commodities; agreements for loans, loan guarantees, interest subsidies, insurance; and programs listed in 2 CFR section 200.101(d) (see Appendix I of this Supplement). Federal awards administered by publicly owned hospitals and other providers of medical care are exempt from 2 CFR Part 200, Subpart E, but are subject to the requirements 45 CFR Part 75, Appendix IX, the Department of Health and Human Services (HHS) implementation of 2 CFR Part 200. The cost principles applicable to a non-federal entity apply to all federal awards received by the entity, regardless of whether the awards are received directly from the federal awarding agency or indirectly through a pass-through entity. For this purpose, federal awards include cost-reimbursement contracts under the Federal Acquisition Regulation (FAR). The cost principles do not apply to federal awards under which a non-federal entity is not required to account to the federal awarding agency or pass-through entity for actual costs incurred.The requirements for allowable costs/cost principles are contained in 2 CFR Part 200, Subpart E, program legislation, federal awarding agency regulations, and the terms and conditions of the award.Basic GuidelinesExcept where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;1. Be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E.2. Conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E or in the federal award as to types or amount of cost items.3. Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity.4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.5. Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only as otherwise provided for in 2 CFR Part 200.6. Not be included as a cost or used to meet cost-sharing or matching requirements of any other federally financed program in either the current or a prior period.7. Be adequately documented.Per 2 CFR Section 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.Condition Found, including PerspectiveIn our testing over allowability of cost, we identified one transaction in a sample of 40 non-payroll transactions for which the University paid and allocated the cost, however, the service contract period had not yet started. In addition, we identified a second transaction for an intergovernmental personnel agreement (in the same sample of 40 non-payroll transactions) which included an advance on future service.Possible Cause and EffectThe University?s internal control over compliance with allowability and allocability was not operating at a level of precision (period of service) consistently through fiscal year 2022.Questioned CostsKnown questioned costs aggregated $52,445 (direct cost + an allocation of indirect costs).Statistical ValidityThe sample was not intended to be, and was not, a statistically valid sample.Repeat Finding in the Prior YearNoRecommendationWe recommend the University enhance the level of precision around its internal control over compliance related to the timing of allocating and charges costs.Views of Responsible OfficialsThe University agrees with this finding. The questioned costs will be removed from the grant charged. Additionally, the University will provide additional education and awareness over the billing of federal awards to ensure that expenses relate to the period being billed and services being performed.
Finding 2022-004: AllowabilityFederal ProgramResearch and Development Cluster (R&D) (AL No.: Various)Federal AgenciesAgencies included within the R&D clusterFederal Award NumberAward numbers: P20GM104316, 1935956Federal Award YearJuly 1, 2021 through June 30, 2022Criteria or RequirementThe cost principles in 2 CFR Part 200, Subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:a. States, local governments, and Indian tribesb. Institutions of higher education (IHEs)c. Nonprofit organizationsAs provided in 2 CFR section 200.101, the cost principles requirements apply to all federal awards with the exception of grant agreements and cooperative agreements providing food commodities; agreements for loans, loan guarantees, interest subsidies, insurance; and programs listed in 2 CFR section 200.101(d) (see Appendix I of this Supplement). Federal awards administered by publicly owned hospitals and other providers of medical care are exempt from 2 CFR Part 200, Subpart E, but are subject to the requirements 45 CFR Part 75, Appendix IX, the Department of Health and Human Services (HHS) implementation of 2 CFR Part 200. The cost principles applicable to a non-federal entity apply to all federal awards received by the entity, regardless of whether the awards are received directly from the federal awarding agency or indirectly through a pass-through entity. For this purpose, federal awards include cost-reimbursement contracts under the Federal Acquisition Regulation (FAR). The cost principles do not apply to federal awards under which a non-federal entity is not required to account to the federal awarding agency or pass-through entity for actual costs incurred.The requirements for allowable costs/cost principles are contained in 2 CFR Part 200, Subpart E, program legislation, federal awarding agency regulations, and the terms and conditions of the award.Basic GuidelinesExcept where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;1. Be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E.2. Conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E or in the federal award as to types or amount of cost items.3. Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity.4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.5. Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only as otherwise provided for in 2 CFR Part 200.6. Not be included as a cost or used to meet cost-sharing or matching requirements of any other federally financed program in either the current or a prior period.7. Be adequately documented.Per 2 CFR Section 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.Condition Found, including PerspectiveIn our testing over allowability of cost, we identified one transaction in a sample of 40 non-payroll transactions for which the University paid and allocated the cost, however, the service contract period had not yet started. In addition, we identified a second transaction for an intergovernmental personnel agreement (in the same sample of 40 non-payroll transactions) which included an advance on future service.Possible Cause and EffectThe University?s internal control over compliance with allowability and allocability was not operating at a level of precision (period of service) consistently through fiscal year 2022.Questioned CostsKnown questioned costs aggregated $52,445 (direct cost + an allocation of indirect costs).Statistical ValidityThe sample was not intended to be, and was not, a statistically valid sample.Repeat Finding in the Prior YearNoRecommendationWe recommend the University enhance the level of precision around its internal control over compliance related to the timing of allocating and charges costs.Views of Responsible OfficialsThe University agrees with this finding. The questioned costs will be removed from the grant charged. Additionally, the University will provide additional education and awareness over the billing of federal awards to ensure that expenses relate to the period being billed and services being performed.
Finding 2022-004: AllowabilityFederal ProgramResearch and Development Cluster (R&D) (AL No.: Various)Federal AgenciesAgencies included within the R&D clusterFederal Award NumberAward numbers: P20GM104316, 1935956Federal Award YearJuly 1, 2021 through June 30, 2022Criteria or RequirementThe cost principles in 2 CFR Part 200, Subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:a. States, local governments, and Indian tribesb. Institutions of higher education (IHEs)c. Nonprofit organizationsAs provided in 2 CFR section 200.101, the cost principles requirements apply to all federal awards with the exception of grant agreements and cooperative agreements providing food commodities; agreements for loans, loan guarantees, interest subsidies, insurance; and programs listed in 2 CFR section 200.101(d) (see Appendix I of this Supplement). Federal awards administered by publicly owned hospitals and other providers of medical care are exempt from 2 CFR Part 200, Subpart E, but are subject to the requirements 45 CFR Part 75, Appendix IX, the Department of Health and Human Services (HHS) implementation of 2 CFR Part 200. The cost principles applicable to a non-federal entity apply to all federal awards received by the entity, regardless of whether the awards are received directly from the federal awarding agency or indirectly through a pass-through entity. For this purpose, federal awards include cost-reimbursement contracts under the Federal Acquisition Regulation (FAR). The cost principles do not apply to federal awards under which a non-federal entity is not required to account to the federal awarding agency or pass-through entity for actual costs incurred.The requirements for allowable costs/cost principles are contained in 2 CFR Part 200, Subpart E, program legislation, federal awarding agency regulations, and the terms and conditions of the award.Basic GuidelinesExcept where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;1. Be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E.2. Conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E or in the federal award as to types or amount of cost items.3. Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity.4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.5. Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only as otherwise provided for in 2 CFR Part 200.6. Not be included as a cost or used to meet cost-sharing or matching requirements of any other federally financed program in either the current or a prior period.7. Be adequately documented.Per 2 CFR Section 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.Condition Found, including PerspectiveIn our testing over allowability of cost, we identified one transaction in a sample of 40 non-payroll transactions for which the University paid and allocated the cost, however, the service contract period had not yet started. In addition, we identified a second transaction for an intergovernmental personnel agreement (in the same sample of 40 non-payroll transactions) which included an advance on future service.Possible Cause and EffectThe University?s internal control over compliance with allowability and allocability was not operating at a level of precision (period of service) consistently through fiscal year 2022.Questioned CostsKnown questioned costs aggregated $52,445 (direct cost + an allocation of indirect costs).Statistical ValidityThe sample was not intended to be, and was not, a statistically valid sample.Repeat Finding in the Prior YearNoRecommendationWe recommend the University enhance the level of precision around its internal control over compliance related to the timing of allocating and charges costs.Views of Responsible OfficialsThe University agrees with this finding. The questioned costs will be removed from the grant charged. Additionally, the University will provide additional education and awareness over the billing of federal awards to ensure that expenses relate to the period being billed and services being performed.