2023-002 Timely Submission of Single Audit Report and Inaccurate Performance Report Numbers Reported Assistance Listing Number: 16.575 Federal Agency: United States Department of Justice Federal Award Identification: Unknown Type of Finding: Material Weakness Compliance Requirement: Reporting Criteria: According to the OMB Compliance Supplement, Part 6 and 2 CFR 200.512 (a)(1), non-federal entities that expend $750,000 or more in federal awards during a fiscal year are required to submit a complete and accurate Data Collection Form (DCF) and a Single Audit report package to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. The DCF is a critical element in ensuring transparency and accountability for the use of federal funds. Additionally, per the Uniform Guidance (200.302) nonfederal entities are required to maintain effective internal controls and proper records to support the financial and performance data used in reporting to federal agencies. This includes maintaining records and documentation to substantiate reported performance and financial information to ensure accuracy, completeness and reliability. Condition: The Agency did not submit the required DCF for the fiscal year ended June 30, 2023, by the required deadline. The Agency also submitted inaccurate reporting for the following grants and timeframes: DV20201438 (4th Quarter), DV22221438 (1st & 2nd Quarters), RC21321438 (3rd Quarter), and RC22331438 (2nd & 3rd Quarter). Cause of Condition: The Agency failed to appropriately monitor and assess its federal expenditures, resulting in the oversight of surpassing the threshold that necessitates a single audit. As a consequence, they have missed the deadline for submission of the required DCF. Also, the Agency's database is not locked from editing and is susceptible to changes leading to inaccuracies when regenerating the report. Counselors responsible for recording their intake numbers are not submitting their numbers on time resulting in untimely recording. The Agency does not have a formal process or procedure in place to ensure that supporting documentation and schedules used in the preparation of performance reports are retained and organized for future reference and audit purposes. Potential Effect of Condition: Failure to submit the DCF on time resulted in noncompliance with federal regulations, which could lead to the potential withholding of future federal funding or other sanctions. It also undermines the Agency's compliance status and may affect the entity's standing with grantor agencies and other stakeholders. Without proper documentation, there is an increased risk of inaccurate or incomplete performance reporting, which may lead to noncompliance with grant requirements. Additionally, the lack of substantiation for reported amounts impairs the Agency's ability to demonstrate compliance with grant objectives and may result in potential audit findings. Questioned Costs: Not quantifiable. Recommendation: We recommend that the Agency implements stronger internal controls and procedures to ensure timely submission of the DCF. This could include designating a responsible party for tracking and submitting the DCF, creating a timeline and checklist for required submissions, and conducting periodic reviews to ensure compliance with deadlines. Additionally, the Agency should provide training to relevant staff on the importance of meeting federal compliance requirements. The client has already implemented a new database system to avoid the cumbersomeness of generating accurate numbers from the old system; however, we recommend a designated employee to ensure counselors are inputting their performance numbers on time. We also recommend a quarterly review of performance numbers before they are reported. Views of Responsible Official: Management agrees with the finding and will implement corrective action.
2023-002 Timely Submission of Single Audit Report and Inaccurate Performance Report Numbers Reported Assistance Listing Number: 16.575 Federal Agency: United States Department of Justice Federal Award Identification: Unknown Type of Finding: Material Weakness Compliance Requirement: Reporting Criteria: According to the OMB Compliance Supplement, Part 6 and 2 CFR 200.512 (a)(1), non-federal entities that expend $750,000 or more in federal awards during a fiscal year are required to submit a complete and accurate Data Collection Form (DCF) and a Single Audit report package to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. The DCF is a critical element in ensuring transparency and accountability for the use of federal funds. Additionally, per the Uniform Guidance (200.302) nonfederal entities are required to maintain effective internal controls and proper records to support the financial and performance data used in reporting to federal agencies. This includes maintaining records and documentation to substantiate reported performance and financial information to ensure accuracy, completeness and reliability. Condition: The Agency did not submit the required DCF for the fiscal year ended June 30, 2023, by the required deadline. The Agency also submitted inaccurate reporting for the following grants and timeframes: DV20201438 (4th Quarter), DV22221438 (1st & 2nd Quarters), RC21321438 (3rd Quarter), and RC22331438 (2nd & 3rd Quarter). Cause of Condition: The Agency failed to appropriately monitor and assess its federal expenditures, resulting in the oversight of surpassing the threshold that necessitates a single audit. As a consequence, they have missed the deadline for submission of the required DCF. Also, the Agency's database is not locked from editing and is susceptible to changes leading to inaccuracies when regenerating the report. Counselors responsible for recording their intake numbers are not submitting their numbers on time resulting in untimely recording. The Agency does not have a formal process or procedure in place to ensure that supporting documentation and schedules used in the preparation of performance reports are retained and organized for future reference and audit purposes. Potential Effect of Condition: Failure to submit the DCF on time resulted in noncompliance with federal regulations, which could lead to the potential withholding of future federal funding or other sanctions. It also undermines the Agency's compliance status and may affect the entity's standing with grantor agencies and other stakeholders. Without proper documentation, there is an increased risk of inaccurate or incomplete performance reporting, which may lead to noncompliance with grant requirements. Additionally, the lack of substantiation for reported amounts impairs the Agency's ability to demonstrate compliance with grant objectives and may result in potential audit findings. Questioned Costs: Not quantifiable. Recommendation: We recommend that the Agency implements stronger internal controls and procedures to ensure timely submission of the DCF. This could include designating a responsible party for tracking and submitting the DCF, creating a timeline and checklist for required submissions, and conducting periodic reviews to ensure compliance with deadlines. Additionally, the Agency should provide training to relevant staff on the importance of meeting federal compliance requirements. The client has already implemented a new database system to avoid the cumbersomeness of generating accurate numbers from the old system; however, we recommend a designated employee to ensure counselors are inputting their performance numbers on time. We also recommend a quarterly review of performance numbers before they are reported. Views of Responsible Official: Management agrees with the finding and will implement corrective action.
2023-002 Timely Submission of Single Audit Report and Inaccurate Performance Report Numbers Reported Assistance Listing Number: 16.575 Federal Agency: United States Department of Justice Federal Award Identification: Unknown Type of Finding: Material Weakness Compliance Requirement: Reporting Criteria: According to the OMB Compliance Supplement, Part 6 and 2 CFR 200.512 (a)(1), non-federal entities that expend $750,000 or more in federal awards during a fiscal year are required to submit a complete and accurate Data Collection Form (DCF) and a Single Audit report package to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. The DCF is a critical element in ensuring transparency and accountability for the use of federal funds. Additionally, per the Uniform Guidance (200.302) nonfederal entities are required to maintain effective internal controls and proper records to support the financial and performance data used in reporting to federal agencies. This includes maintaining records and documentation to substantiate reported performance and financial information to ensure accuracy, completeness and reliability. Condition: The Agency did not submit the required DCF for the fiscal year ended June 30, 2023, by the required deadline. The Agency also submitted inaccurate reporting for the following grants and timeframes: DV20201438 (4th Quarter), DV22221438 (1st & 2nd Quarters), RC21321438 (3rd Quarter), and RC22331438 (2nd & 3rd Quarter). Cause of Condition: The Agency failed to appropriately monitor and assess its federal expenditures, resulting in the oversight of surpassing the threshold that necessitates a single audit. As a consequence, they have missed the deadline for submission of the required DCF. Also, the Agency's database is not locked from editing and is susceptible to changes leading to inaccuracies when regenerating the report. Counselors responsible for recording their intake numbers are not submitting their numbers on time resulting in untimely recording. The Agency does not have a formal process or procedure in place to ensure that supporting documentation and schedules used in the preparation of performance reports are retained and organized for future reference and audit purposes. Potential Effect of Condition: Failure to submit the DCF on time resulted in noncompliance with federal regulations, which could lead to the potential withholding of future federal funding or other sanctions. It also undermines the Agency's compliance status and may affect the entity's standing with grantor agencies and other stakeholders. Without proper documentation, there is an increased risk of inaccurate or incomplete performance reporting, which may lead to noncompliance with grant requirements. Additionally, the lack of substantiation for reported amounts impairs the Agency's ability to demonstrate compliance with grant objectives and may result in potential audit findings. Questioned Costs: Not quantifiable. Recommendation: We recommend that the Agency implements stronger internal controls and procedures to ensure timely submission of the DCF. This could include designating a responsible party for tracking and submitting the DCF, creating a timeline and checklist for required submissions, and conducting periodic reviews to ensure compliance with deadlines. Additionally, the Agency should provide training to relevant staff on the importance of meeting federal compliance requirements. The client has already implemented a new database system to avoid the cumbersomeness of generating accurate numbers from the old system; however, we recommend a designated employee to ensure counselors are inputting their performance numbers on time. We also recommend a quarterly review of performance numbers before they are reported. Views of Responsible Official: Management agrees with the finding and will implement corrective action.
FINDING 2023-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013, S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include proper segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were compiled, prepared, and submitted by one employee without documentation to support an oversight or review process to prevent, or detect and correct, errors. In addition, the School Corporation was unable to provide supporting documentation for any of the information contained in the six reports submitted during the audit period. Ledgers and reimbursement requests were used to verify the information in three of the six reports; however, the other three reports could not be substantiated. The following errors were noted: The ESSER II, Year 2 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The ESSER III, Year 1 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The ESSER III, Year 2 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to the three reports noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, ESSER reports were not supported by the School Corporation's records, were not accurate and complete, and were not mathematically accurate. Additionally, key line items were not supported by the records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure supporting documentation is used and retained for all required reports submitted on behalf of the Education Stabilization Fund program funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013, S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include proper segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were compiled, prepared, and submitted by one employee without documentation to support an oversight or review process to prevent, or detect and correct, errors. In addition, the School Corporation was unable to provide supporting documentation for any of the information contained in the six reports submitted during the audit period. Ledgers and reimbursement requests were used to verify the information in three of the six reports; however, the other three reports could not be substantiated. The following errors were noted: The ESSER II, Year 2 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The ESSER III, Year 1 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The ESSER III, Year 2 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to the three reports noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, ESSER reports were not supported by the School Corporation's records, were not accurate and complete, and were not mathematically accurate. Additionally, key line items were not supported by the records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure supporting documentation is used and retained for all required reports submitted on behalf of the Education Stabilization Fund program funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013, S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include proper segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were compiled, prepared, and submitted by one employee without documentation to support an oversight or review process to prevent, or detect and correct, errors. In addition, the School Corporation was unable to provide supporting documentation for any of the information contained in the six reports submitted during the audit period. Ledgers and reimbursement requests were used to verify the information in three of the six reports; however, the other three reports could not be substantiated. The following errors were noted: The ESSER II, Year 2 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The ESSER III, Year 1 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The ESSER III, Year 2 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to the three reports noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, ESSER reports were not supported by the School Corporation's records, were not accurate and complete, and were not mathematically accurate. Additionally, key line items were not supported by the records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure supporting documentation is used and retained for all required reports submitted on behalf of the Education Stabilization Fund program funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013, S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include proper segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were compiled, prepared, and submitted by one employee without documentation to support an oversight or review process to prevent, or detect and correct, errors. In addition, the School Corporation was unable to provide supporting documentation for any of the information contained in the six reports submitted during the audit period. Ledgers and reimbursement requests were used to verify the information in three of the six reports; however, the other three reports could not be substantiated. The following errors were noted: The ESSER II, Year 2 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The ESSER III, Year 1 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The ESSER III, Year 2 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to the three reports noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, ESSER reports were not supported by the School Corporation's records, were not accurate and complete, and were not mathematically accurate. Additionally, key line items were not supported by the records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure supporting documentation is used and retained for all required reports submitted on behalf of the Education Stabilization Fund program funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013, S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include proper segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were compiled, prepared, and submitted by one employee without documentation to support an oversight or review process to prevent, or detect and correct, errors. In addition, the School Corporation was unable to provide supporting documentation for any of the information contained in the six reports submitted during the audit period. Ledgers and reimbursement requests were used to verify the information in three of the six reports; however, the other three reports could not be substantiated. The following errors were noted: The ESSER II, Year 2 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The ESSER III, Year 1 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The ESSER III, Year 2 report was not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to the three reports noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, ESSER reports were not supported by the School Corporation's records, were not accurate and complete, and were not mathematically accurate. Additionally, key line items were not supported by the records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure supporting documentation is used and retained for all required reports submitted on behalf of the Education Stabilization Fund program funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-004 Subject: Twenty-First Century Community Learning Centers - Cash Management, Program Income and Reporting Federal Agency: Department of Education Federal Program: Twenty-First Century Community Learning Centers Assistance Listings Number: 84.287 Federal Award Numbers and Years (or Other Identifying Numbers): A58-1-21DL-0153, A58-1-21DL-5176, A58-2-22DL-0018, A58-3-23DL-0027 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Cash Management, Program Income, and Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation utilized grant funds to operate an After School Care Safe Harbor Program. As part of the programs, the students were charged monthly fees to help cover the related costs. Per the grant guidelines, families cannot be turned away for nonpayment of fees, and any fees collected are to be reinvested into the programs. Reimbursement requests are to deduct the program income received from allowable costs prior to claiming reimbursement. During the audit period, the School Corporation collected fees for the Before School Care Program and the After School Care Safe Harbor Program in the same manner. Fees collected for both programs were collected and receipted into the After School fund. For the years ended June 30, 2022, and June 30, 2023, the School Corporation receipted a total of $45,723 and $41,513, respectively, into the After School fund. Cash Management The School Corporation submitted 18 reimbursement requests in the audit period. Costs were paid prior to requesting reimbursement as required; however, due to the lack of adequate program income records the reimbursements were not reduced by the program income received. INDIANA STATE BOARD OF ACCOUNTS 26 MICHIGAN CITY AREA SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Program Income Although the School Corporation received approval from the grantor agency to collect program income, the School Corporation did not properly track students' attendance and payments, both if paid and how much paid; therefore, we were unable to determine the amount of program income related to each program. Additionally, the School Corporation did not maintain program income in a separate fund but comingled it with other nongrant funded program revenues. Finally, the School Corporation did not deduct program income from allowable costs prior to claiming reimbursement. Reporting Reimbursement Requests The School Corporation submitted 18 reimbursement requests in the audit period. Of those, 3 reimbursement requests were selected for testing. Of the 3 reimbursement requests inspected, none were reduced by program income received, and 1 was not properly supported by School Corporation records. The reimbursement was overstated by $14,700 when compared to the ledger. Based on additional procedures performed, the total requested reimbursements for the audit period were understated by $32,605 when compared to the ledger. Year End Reports End of Year reports are to be submitted within 60 days of the contract end date. A total of four End of Year Reports were submitted in the audit period and two were selected for testing. Of the two End of Year reports selected for testing, neither properly included program income received during the year due to inadequate tracking of program income. The lack of controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.305(b)(5) states in part: "To the extent available, the non-Federal entity must disburse funds available from program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries, and interest earned on such funds before requesting additional cash payments." INDIANA STATE BOARD OF ACCOUNTS 27 MICHIGAN CITY AREA SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.307 states in part: "(a) General. Non-Federal entities are encouraged to earn income to defray program costs where appropriate. . . . (e) Use of program income. If the Federal awarding agency does not specify in its regulations or the terms and conditions of the Federal award, or give prior approval for how program income is to be used, paragraph (e)(1) of this section must apply. For Federal awards made to IHEs and nonprofit research institutions, if the Federal awarding agency does not specify in its regulations or the terms and conditions of the Federal award how program income is to be used, paragraph (e)(2) of this section must apply. In specifying alternatives to paragraphs (e)(1) and (2) of this section, the Federal awarding agency may distinguish between income earned by the recipient and income earned by subrecipients and between the sources, kinds, or amounts of income. When the Federal awarding agency authorizes the approaches in paragraphs (e)(2) and (3) of this section, program income in excess of any amounts specified must also be deducted from expenditures. (1) Deduction. Ordinarily program income must be deducted from total allowable costs to determine the net allowable costs. Program income must be used for current costs unless the Federal awarding agency authorizes otherwise. Program income that the non- Federal entity did not anticipate at the time of the Federal award must be used to reduce the Federal award and non- Federal entity contributions rather than to increase the funds committed to the project. (2) Addition. With prior approval of the Federal awarding agency (except for IHEs and nonprofit research institutions, as described in this paragraph (e)) program income may be added to the Federal award by the Federal agency and the non-Federal entity. The program income must be used for the purposes and under the conditions of the Federal award. (3) Cost sharing or matching. With prior approval of the Federal awarding agency, program income may be used to meet the cost sharing or matching requirement of the Federal award. The amount of the Federal award remains the same. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." INDIANA STATE BOARD OF ACCOUNTS 28 MICHIGAN CITY AREA SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, program income was not properly documented resulting in noncompliance with the Cash Management, Program Income, and Reporting compliance requirements. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding by the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and strengthen its policies and procedures to ensure proper tracking of program income to ensure all activity and reports submitted on behalf of the Twenty-First Century Community Learning Centers program funds are accurate. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-004 Subject: Twenty-First Century Community Learning Centers - Cash Management, Program Income and Reporting Federal Agency: Department of Education Federal Program: Twenty-First Century Community Learning Centers Assistance Listings Number: 84.287 Federal Award Numbers and Years (or Other Identifying Numbers): A58-1-21DL-0153, A58-1-21DL-5176, A58-2-22DL-0018, A58-3-23DL-0027 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Cash Management, Program Income, and Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation utilized grant funds to operate an After School Care Safe Harbor Program. As part of the programs, the students were charged monthly fees to help cover the related costs. Per the grant guidelines, families cannot be turned away for nonpayment of fees, and any fees collected are to be reinvested into the programs. Reimbursement requests are to deduct the program income received from allowable costs prior to claiming reimbursement. During the audit period, the School Corporation collected fees for the Before School Care Program and the After School Care Safe Harbor Program in the same manner. Fees collected for both programs were collected and receipted into the After School fund. For the years ended June 30, 2022, and June 30, 2023, the School Corporation receipted a total of $45,723 and $41,513, respectively, into the After School fund. Cash Management The School Corporation submitted 18 reimbursement requests in the audit period. Costs were paid prior to requesting reimbursement as required; however, due to the lack of adequate program income records the reimbursements were not reduced by the program income received. INDIANA STATE BOARD OF ACCOUNTS 26 MICHIGAN CITY AREA SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Program Income Although the School Corporation received approval from the grantor agency to collect program income, the School Corporation did not properly track students' attendance and payments, both if paid and how much paid; therefore, we were unable to determine the amount of program income related to each program. Additionally, the School Corporation did not maintain program income in a separate fund but comingled it with other nongrant funded program revenues. Finally, the School Corporation did not deduct program income from allowable costs prior to claiming reimbursement. Reporting Reimbursement Requests The School Corporation submitted 18 reimbursement requests in the audit period. Of those, 3 reimbursement requests were selected for testing. Of the 3 reimbursement requests inspected, none were reduced by program income received, and 1 was not properly supported by School Corporation records. The reimbursement was overstated by $14,700 when compared to the ledger. Based on additional procedures performed, the total requested reimbursements for the audit period were understated by $32,605 when compared to the ledger. Year End Reports End of Year reports are to be submitted within 60 days of the contract end date. A total of four End of Year Reports were submitted in the audit period and two were selected for testing. Of the two End of Year reports selected for testing, neither properly included program income received during the year due to inadequate tracking of program income. The lack of controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.305(b)(5) states in part: "To the extent available, the non-Federal entity must disburse funds available from program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries, and interest earned on such funds before requesting additional cash payments." INDIANA STATE BOARD OF ACCOUNTS 27 MICHIGAN CITY AREA SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.307 states in part: "(a) General. Non-Federal entities are encouraged to earn income to defray program costs where appropriate. . . . (e) Use of program income. If the Federal awarding agency does not specify in its regulations or the terms and conditions of the Federal award, or give prior approval for how program income is to be used, paragraph (e)(1) of this section must apply. For Federal awards made to IHEs and nonprofit research institutions, if the Federal awarding agency does not specify in its regulations or the terms and conditions of the Federal award how program income is to be used, paragraph (e)(2) of this section must apply. In specifying alternatives to paragraphs (e)(1) and (2) of this section, the Federal awarding agency may distinguish between income earned by the recipient and income earned by subrecipients and between the sources, kinds, or amounts of income. When the Federal awarding agency authorizes the approaches in paragraphs (e)(2) and (3) of this section, program income in excess of any amounts specified must also be deducted from expenditures. (1) Deduction. Ordinarily program income must be deducted from total allowable costs to determine the net allowable costs. Program income must be used for current costs unless the Federal awarding agency authorizes otherwise. Program income that the non- Federal entity did not anticipate at the time of the Federal award must be used to reduce the Federal award and non- Federal entity contributions rather than to increase the funds committed to the project. (2) Addition. With prior approval of the Federal awarding agency (except for IHEs and nonprofit research institutions, as described in this paragraph (e)) program income may be added to the Federal award by the Federal agency and the non-Federal entity. The program income must be used for the purposes and under the conditions of the Federal award. (3) Cost sharing or matching. With prior approval of the Federal awarding agency, program income may be used to meet the cost sharing or matching requirement of the Federal award. The amount of the Federal award remains the same. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." INDIANA STATE BOARD OF ACCOUNTS 28 MICHIGAN CITY AREA SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, program income was not properly documented resulting in noncompliance with the Cash Management, Program Income, and Reporting compliance requirements. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding by the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and strengthen its policies and procedures to ensure proper tracking of program income to ensure all activity and reports submitted on behalf of the Twenty-First Century Community Learning Centers program funds are accurate. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-007 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425 Federal Award Numbers and Years (or Other Identifying Numbers): 5120S425U210013, S425U200013, S425V200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. INDIANA STATE BOARD OF ACCOUNTS 33 MICHIGAN CITY AREA SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) During the audit period, the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. Two of the six reports submitted during the audit period were not supported by the School Corporation's records. The following errors were identified: The ESSER II, Year 2 report, which covered the period of July 1, 2021 to June 30, 2022, reported $4,608,835 in total expenditures. However, the School Corporation's ledger for the same period had total expenditures of $4,560,160. The ESSER III, Year 2 report, which had covered the period of July 1, 2021 to June 30, 2022, reported $118,103 in total expenditures. However, the School Corporation's ledger for the same period had total expenditures of $317,536. The lack of internal controls and noncompliance were isolated to these two reports. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. INDIANA STATE BOARD OF ACCOUNTS 34 MICHIGAN CITY AREA SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, ESSER reports were not supported by the School Corporation's records and were not accurate and complete. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all reports are submitted accurately. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-007 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425 Federal Award Numbers and Years (or Other Identifying Numbers): 5120S425U210013, S425U200013, S425V200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. INDIANA STATE BOARD OF ACCOUNTS 33 MICHIGAN CITY AREA SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) During the audit period, the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. Two of the six reports submitted during the audit period were not supported by the School Corporation's records. The following errors were identified: The ESSER II, Year 2 report, which covered the period of July 1, 2021 to June 30, 2022, reported $4,608,835 in total expenditures. However, the School Corporation's ledger for the same period had total expenditures of $4,560,160. The ESSER III, Year 2 report, which had covered the period of July 1, 2021 to June 30, 2022, reported $118,103 in total expenditures. However, the School Corporation's ledger for the same period had total expenditures of $317,536. The lack of internal controls and noncompliance were isolated to these two reports. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. INDIANA STATE BOARD OF ACCOUNTS 34 MICHIGAN CITY AREA SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, ESSER reports were not supported by the School Corporation's records and were not accurate and complete. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all reports are submitted accurately. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-007 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425 Federal Award Numbers and Years (or Other Identifying Numbers): 5120S425U210013, S425U200013, S425V200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. INDIANA STATE BOARD OF ACCOUNTS 33 MICHIGAN CITY AREA SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) During the audit period, the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. Two of the six reports submitted during the audit period were not supported by the School Corporation's records. The following errors were identified: The ESSER II, Year 2 report, which covered the period of July 1, 2021 to June 30, 2022, reported $4,608,835 in total expenditures. However, the School Corporation's ledger for the same period had total expenditures of $4,560,160. The ESSER III, Year 2 report, which had covered the period of July 1, 2021 to June 30, 2022, reported $118,103 in total expenditures. However, the School Corporation's ledger for the same period had total expenditures of $317,536. The lack of internal controls and noncompliance were isolated to these two reports. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. INDIANA STATE BOARD OF ACCOUNTS 34 MICHIGAN CITY AREA SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, ESSER reports were not supported by the School Corporation's records and were not accurate and complete. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all reports are submitted accurately. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-007 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425 Federal Award Numbers and Years (or Other Identifying Numbers): 5120S425U210013, S425U200013, S425V200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. INDIANA STATE BOARD OF ACCOUNTS 33 MICHIGAN CITY AREA SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) During the audit period, the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. Two of the six reports submitted during the audit period were not supported by the School Corporation's records. The following errors were identified: The ESSER II, Year 2 report, which covered the period of July 1, 2021 to June 30, 2022, reported $4,608,835 in total expenditures. However, the School Corporation's ledger for the same period had total expenditures of $4,560,160. The ESSER III, Year 2 report, which had covered the period of July 1, 2021 to June 30, 2022, reported $118,103 in total expenditures. However, the School Corporation's ledger for the same period had total expenditures of $317,536. The lack of internal controls and noncompliance were isolated to these two reports. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. INDIANA STATE BOARD OF ACCOUNTS 34 MICHIGAN CITY AREA SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, ESSER reports were not supported by the School Corporation's records and were not accurate and complete. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all reports are submitted accurately. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds. Cause: Insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Effect or Potential Effect: Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs. Questioned Costs: Below reporting threshold. Context: • For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation. • For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-014. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures. Views of Responsible Officials: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025.