2 CFR 200 § 200.302

Findings Citing § 200.302

Financial management.

Total Findings
17,038
Across all audits in database
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About this section
Section 200.302 requires states to manage and account for federal awards according to their laws, ensuring financial systems track expenditures and comply with federal regulations. This affects state recipients and subrecipients by mandating accurate reporting and record-keeping for all federal funds received and spent.
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FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
The Howard University
Compliance Requirement: B
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 con...

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.

FY End: 2023-06-30
Town of Livermore Falls
Compliance Requirement: C
2023-006 - Cash Management Federal Program Information: ALN - 66.458 - Clean Water State Revolving Funds Criteria: The following CFR(s) apply to this finding: 2 CFR section 200.302(b)(6)) & 2 CFR section 200.305(b) (3). Condition: During audit procedures, it was identified that the Town did not have a cash management policy in place. Cause: The Town has experienced turnover in the Treasurer’s position over the past few years, which has delayed the policy implementation. Effect: The Town may not ...

2023-006 - Cash Management Federal Program Information: ALN - 66.458 - Clean Water State Revolving Funds Criteria: The following CFR(s) apply to this finding: 2 CFR section 200.302(b)(6)) & 2 CFR section 200.305(b) (3). Condition: During audit procedures, it was identified that the Town did not have a cash management policy in place. Cause: The Town has experienced turnover in the Treasurer’s position over the past few years, which has delayed the policy implementation. Effect: The Town may not have adequate policy and procedures in place to safeguard its most liquid assets. Identification of Questioned Costs: None identified. Context: The population consisted of 6 out of 10 pay requisites deposit of reimbursements from the fiscal year were examined. Out of the 6 selections all 6 were not properly recorded. Repeat Finding: This is a repeat finding of 2022-007. Recommendation: It is recommended that the Town adopt a cash management policy that follows the Uniform Guidance and that the Town implement internal control processes and procedures to ensure that the adopted policy is followed. Views of Responsible Officials and Corrective Action Plan: Client agrees with finding and a version of their response can be found in the Corrective Action Plan. Please see the Corrective Action Plan issued by the Town of Livermore Falls.

FY End: 2023-06-30
Town of Livermore Falls
Compliance Requirement: C
2023-006 - Cash Management Federal Program Information: ALN - 66.458 - Clean Water State Revolving Funds Criteria: The following CFR(s) apply to this finding: 2 CFR section 200.302(b)(6)) & 2 CFR section 200.305(b) (3). Condition: During audit procedures, it was identified that the Town did not have a cash management policy in place. Cause: The Town has experienced turnover in the Treasurer’s position over the past few years, which has delayed the policy implementation. Effect: The Town may not ...

2023-006 - Cash Management Federal Program Information: ALN - 66.458 - Clean Water State Revolving Funds Criteria: The following CFR(s) apply to this finding: 2 CFR section 200.302(b)(6)) & 2 CFR section 200.305(b) (3). Condition: During audit procedures, it was identified that the Town did not have a cash management policy in place. Cause: The Town has experienced turnover in the Treasurer’s position over the past few years, which has delayed the policy implementation. Effect: The Town may not have adequate policy and procedures in place to safeguard its most liquid assets. Identification of Questioned Costs: None identified. Context: The population consisted of 6 out of 10 pay requisites deposit of reimbursements from the fiscal year were examined. Out of the 6 selections all 6 were not properly recorded. Repeat Finding: This is a repeat finding of 2022-007. Recommendation: It is recommended that the Town adopt a cash management policy that follows the Uniform Guidance and that the Town implement internal control processes and procedures to ensure that the adopted policy is followed. Views of Responsible Officials and Corrective Action Plan: Client agrees with finding and a version of their response can be found in the Corrective Action Plan. Please see the Corrective Action Plan issued by the Town of Livermore Falls.

FY End: 2023-06-30
Town of Livermore Falls
Compliance Requirement: C
2023-006 - Cash Management Federal Program Information: ALN - 66.458 - Clean Water State Revolving Funds Criteria: The following CFR(s) apply to this finding: 2 CFR section 200.302(b)(6)) & 2 CFR section 200.305(b) (3). Condition: During audit procedures, it was identified that the Town did not have a cash management policy in place. Cause: The Town has experienced turnover in the Treasurer’s position over the past few years, which has delayed the policy implementation. Effect: The Town may not ...

2023-006 - Cash Management Federal Program Information: ALN - 66.458 - Clean Water State Revolving Funds Criteria: The following CFR(s) apply to this finding: 2 CFR section 200.302(b)(6)) & 2 CFR section 200.305(b) (3). Condition: During audit procedures, it was identified that the Town did not have a cash management policy in place. Cause: The Town has experienced turnover in the Treasurer’s position over the past few years, which has delayed the policy implementation. Effect: The Town may not have adequate policy and procedures in place to safeguard its most liquid assets. Identification of Questioned Costs: None identified. Context: The population consisted of 6 out of 10 pay requisites deposit of reimbursements from the fiscal year were examined. Out of the 6 selections all 6 were not properly recorded. Repeat Finding: This is a repeat finding of 2022-007. Recommendation: It is recommended that the Town adopt a cash management policy that follows the Uniform Guidance and that the Town implement internal control processes and procedures to ensure that the adopted policy is followed. Views of Responsible Officials and Corrective Action Plan: Client agrees with finding and a version of their response can be found in the Corrective Action Plan. Please see the Corrective Action Plan issued by the Town of Livermore Falls.

FY End: 2023-06-30
Town of Livermore Falls
Compliance Requirement: C
2023-006 - Cash Management Federal Program Information: ALN - 66.458 - Clean Water State Revolving Funds Criteria: The following CFR(s) apply to this finding: 2 CFR section 200.302(b)(6)) & 2 CFR section 200.305(b) (3). Condition: During audit procedures, it was identified that the Town did not have a cash management policy in place. Cause: The Town has experienced turnover in the Treasurer’s position over the past few years, which has delayed the policy implementation. Effect: The Town may not ...

2023-006 - Cash Management Federal Program Information: ALN - 66.458 - Clean Water State Revolving Funds Criteria: The following CFR(s) apply to this finding: 2 CFR section 200.302(b)(6)) & 2 CFR section 200.305(b) (3). Condition: During audit procedures, it was identified that the Town did not have a cash management policy in place. Cause: The Town has experienced turnover in the Treasurer’s position over the past few years, which has delayed the policy implementation. Effect: The Town may not have adequate policy and procedures in place to safeguard its most liquid assets. Identification of Questioned Costs: None identified. Context: The population consisted of 6 out of 10 pay requisites deposit of reimbursements from the fiscal year were examined. Out of the 6 selections all 6 were not properly recorded. Repeat Finding: This is a repeat finding of 2022-007. Recommendation: It is recommended that the Town adopt a cash management policy that follows the Uniform Guidance and that the Town implement internal control processes and procedures to ensure that the adopted policy is followed. Views of Responsible Officials and Corrective Action Plan: Client agrees with finding and a version of their response can be found in the Corrective Action Plan. Please see the Corrective Action Plan issued by the Town of Livermore Falls.

FY End: 2023-06-30
City of Baltimore, Maryland
Compliance Requirement: L
U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the no...

U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, 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. In accordance with 2 CFR 200.302: Financial management. (a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state’s own funds. In addition, the state’s and the other non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The agency did not have controls in place to ensure a complete Federal Financial Report was submitted. Effect: Expenditures reported to the Federal government were inaccurate. Questioned Costs: None. Recommendation: We recommend the City establish and implement a process to reconcile reports used by the various departments for external reporting to the City’s internal records to validate compliance with reporting requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.

FY End: 2023-06-30
City of Baltimore, Maryland
Compliance Requirement: L
U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the no...

U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, 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. In accordance with 2 CFR 200.302: Financial management. (a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state’s own funds. In addition, the state’s and the other non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The agency did not have controls in place to ensure a complete Federal Financial Report was submitted. Effect: Expenditures reported to the Federal government were inaccurate. Questioned Costs: None. Recommendation: We recommend the City establish and implement a process to reconcile reports used by the various departments for external reporting to the City’s internal records to validate compliance with reporting requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.

FY End: 2023-06-30
City of Baltimore, Maryland
Compliance Requirement: L
U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the no...

U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, 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. In accordance with 2 CFR 200.302: Financial management. (a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state’s own funds. In addition, the state’s and the other non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The agency did not have controls in place to ensure a complete Federal Financial Report was submitted. Effect: Expenditures reported to the Federal government were inaccurate. Questioned Costs: None. Recommendation: We recommend the City establish and implement a process to reconcile reports used by the various departments for external reporting to the City’s internal records to validate compliance with reporting requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.

FY End: 2023-06-30
City of Baltimore, Maryland
Compliance Requirement: L
U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the no...

U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, 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. In accordance with 2 CFR 200.302: Financial management. (a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state’s own funds. In addition, the state’s and the other non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The agency did not have controls in place to ensure a complete Federal Financial Report was submitted. Effect: Expenditures reported to the Federal government were inaccurate. Questioned Costs: None. Recommendation: We recommend the City establish and implement a process to reconcile reports used by the various departments for external reporting to the City’s internal records to validate compliance with reporting requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.

FY End: 2023-06-30
City of Baltimore, Maryland
Compliance Requirement: L
U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the no...

U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, 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. In accordance with 2 CFR 200.302: Financial management. (a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state’s own funds. In addition, the state’s and the other non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The agency did not have controls in place to ensure a complete Federal Financial Report was submitted. Effect: Expenditures reported to the Federal government were inaccurate. Questioned Costs: None. Recommendation: We recommend the City establish and implement a process to reconcile reports used by the various departments for external reporting to the City’s internal records to validate compliance with reporting requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.

FY End: 2023-06-30
City of Baltimore, Maryland
Compliance Requirement: L
U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the no...

U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, 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. In accordance with 2 CFR 200.302: Financial management. (a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state’s own funds. In addition, the state’s and the other non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The agency did not have controls in place to ensure a complete Federal Financial Report was submitted. Effect: Expenditures reported to the Federal government were inaccurate. Questioned Costs: None. Recommendation: We recommend the City establish and implement a process to reconcile reports used by the various departments for external reporting to the City’s internal records to validate compliance with reporting requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.

FY End: 2023-06-30
City of Baltimore, Maryland
Compliance Requirement: L
U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the no...

U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, 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. In accordance with 2 CFR 200.302: Financial management. (a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state’s own funds. In addition, the state’s and the other non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The agency did not have controls in place to ensure a complete Federal Financial Report was submitted. Effect: Expenditures reported to the Federal government were inaccurate. Questioned Costs: None. Recommendation: We recommend the City establish and implement a process to reconcile reports used by the various departments for external reporting to the City’s internal records to validate compliance with reporting requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.

FY End: 2023-06-30
City of Baltimore, Maryland
Compliance Requirement: L
U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the no...

U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, 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. In accordance with 2 CFR 200.302: Financial management. (a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state’s own funds. In addition, the state’s and the other non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The agency did not have controls in place to ensure a complete Federal Financial Report was submitted. Effect: Expenditures reported to the Federal government were inaccurate. Questioned Costs: None. Recommendation: We recommend the City establish and implement a process to reconcile reports used by the various departments for external reporting to the City’s internal records to validate compliance with reporting requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.

FY End: 2023-06-30
City of Baltimore, Maryland
Compliance Requirement: L
U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the no...

U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, 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. In accordance with 2 CFR 200.302: Financial management. (a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state’s own funds. In addition, the state’s and the other non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The agency did not have controls in place to ensure a complete Federal Financial Report was submitted. Effect: Expenditures reported to the Federal government were inaccurate. Questioned Costs: None. Recommendation: We recommend the City establish and implement a process to reconcile reports used by the various departments for external reporting to the City’s internal records to validate compliance with reporting requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.

FY End: 2023-06-30
City of Baltimore, Maryland
Compliance Requirement: L
U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the no...

U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, 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. In accordance with 2 CFR 200.302: Financial management. (a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state’s own funds. In addition, the state’s and the other non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The agency did not have controls in place to ensure a complete Federal Financial Report was submitted. Effect: Expenditures reported to the Federal government were inaccurate. Questioned Costs: None. Recommendation: We recommend the City establish and implement a process to reconcile reports used by the various departments for external reporting to the City’s internal records to validate compliance with reporting requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.

FY End: 2023-06-30
City of Baltimore, Maryland
Compliance Requirement: L
U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the no...

U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, 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. In accordance with 2 CFR 200.302: Financial management. (a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state’s own funds. In addition, the state’s and the other non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The agency did not have controls in place to ensure a complete Federal Financial Report was submitted. Effect: Expenditures reported to the Federal government were inaccurate. Questioned Costs: None. Recommendation: We recommend the City establish and implement a process to reconcile reports used by the various departments for external reporting to the City’s internal records to validate compliance with reporting requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.

FY End: 2023-06-30
City of Baltimore, Maryland
Compliance Requirement: L
U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the no...

U.S. Department of Health and Human Services AL No. 93.044, 93.045, 93.053 Aging Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: The Federal Financial Report provided by management did not include amounts spent under the Federal award. Criteria: In accordance with 2 CFR §200.303, 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. In accordance with 2 CFR 200.302: Financial management. (a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state’s own funds. In addition, the state’s and the other non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The agency did not have controls in place to ensure a complete Federal Financial Report was submitted. Effect: Expenditures reported to the Federal government were inaccurate. Questioned Costs: None. Recommendation: We recommend the City establish and implement a process to reconcile reports used by the various departments for external reporting to the City’s internal records to validate compliance with reporting requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.

FY End: 2023-06-30
City of Baltimore, Maryland
Compliance Requirement: C
U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Material Weakness in Internal Controls and Noncompliance over Cash Management Repeat Finding: No Condition: For 4 out of 4 selections, we were unable to agree the drawdown amount to the general ledger to ensure funds were being expended prior to requesting reimbursement. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effecti...

U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Material Weakness in Internal Controls and Noncompliance over Cash Management Repeat Finding: No Condition: For 4 out of 4 selections, we were unable to agree the drawdown amount to the general ledger to ensure funds were being expended prior to requesting reimbursement. Criteria: In accordance with 2 CFR 200.303: Internal Control, 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. In accordance with 2 CFR 200.302: Financial management. (a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state’s own funds. In addition, the state’s and the other non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. According to AM 413-60, Grant Documentation, Grant Manager/Program Manager/Director conducts ongoing monitoring and control of all reimbursement receipts and deposits until grant ends; as well as all program and sub-recipient (when applicable) documentation, to include: (1) program documentation; (2) timesheets; (3) deliverables; (4) activities; (5) vendor payments; (6) program data/charts/numbers; and (7) financial and compliance report. According to AM 413-61, Grant Management Financial Reporting, Grant Manager/Program Manager/Director maintains all documentation, either electronic or hard copy, for all Federally funded grants for the term of the grant for a minimum of seven years for review and audit by the granting agency or its designee. Cause: The agency could not reconcile information presented in the expenditure report to the underlying records. Finance and the agency use different parameters for generating reports and there was no documentation of the reconciling differences. Effect: The City may not be in compliance with the cash management requirements in accordance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement a process to reconcile reports used by the various departments for external reporting to the City’s internal records to validate compliance with cash management requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.

FY End: 2023-06-30
City of Baltimore, Maryland
Compliance Requirement: L
U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: For 1 out of 1 selection, we were unable to agree the expenditure details from the general ledger to the amounts reported in the Federal Financial Report to ensure completeness, accuracy and compliance with the required accounting basis. For 1 out of 1 selection, we noted that the Federal ...

U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: For 1 out of 1 selection, we were unable to agree the expenditure details from the general ledger to the amounts reported in the Federal Financial Report to ensure completeness, accuracy and compliance with the required accounting basis. For 1 out of 1 selection, we noted that the Federal Financial Report was not submitted timely. Criteria: In accordance with 2 CFR §200.303, 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. In accordance with 2 CFR 200.302: Financial management. (a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state’s own funds. In addition, the state’s and the other non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Additionally, the grant agreement requires the Federal Financial Report to be submitted no later than 90 days after the period of performance end date through recipient online accounts in the Payment Management System. Cause: The agency could not reconcile information reported in the expenditure report to the state to the underlying records. Finance and the agency use different parameters for running reports and neither department reconciled the other reporting completed. Effect: Expenditures reported to the Federal government could be inaccurate. Questioned Costs: None. Recommendation: We recommend the City establish and implement a process to reconcile reports used by the various departments for external reporting to the City’s internal records to validate compliance with reporting requirements. Additionally, there should be a process to ensure all reports are submitted timely. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.

FY End: 2023-06-30
City of Baltimore, Maryland
Compliance Requirement: C
U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Material Weakness in Internal Controls and Noncompliance over Cash Management Repeat Finding: No Condition: For 4 out of 4 selections, we were unable to agree the drawdown amount to the general ledger to ensure funds were being expended prior to requesting reimbursement. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effecti...

U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Material Weakness in Internal Controls and Noncompliance over Cash Management Repeat Finding: No Condition: For 4 out of 4 selections, we were unable to agree the drawdown amount to the general ledger to ensure funds were being expended prior to requesting reimbursement. Criteria: In accordance with 2 CFR 200.303: Internal Control, 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. In accordance with 2 CFR 200.302: Financial management. (a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state’s own funds. In addition, the state’s and the other non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. According to AM 413-60, Grant Documentation, Grant Manager/Program Manager/Director conducts ongoing monitoring and control of all reimbursement receipts and deposits until grant ends; as well as all program and sub-recipient (when applicable) documentation, to include: (1) program documentation; (2) timesheets; (3) deliverables; (4) activities; (5) vendor payments; (6) program data/charts/numbers; and (7) financial and compliance report. According to AM 413-61, Grant Management Financial Reporting, Grant Manager/Program Manager/Director maintains all documentation, either electronic or hard copy, for all Federally funded grants for the term of the grant for a minimum of seven years for review and audit by the granting agency or its designee. Cause: The agency could not reconcile information presented in the expenditure report to the underlying records. Finance and the agency use different parameters for generating reports and there was no documentation of the reconciling differences. Effect: The City may not be in compliance with the cash management requirements in accordance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement a process to reconcile reports used by the various departments for external reporting to the City’s internal records to validate compliance with cash management requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.

FY End: 2023-06-30
City of Baltimore, Maryland
Compliance Requirement: L
U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: For 1 out of 1 selection, we were unable to agree the expenditure details from the general ledger to the amounts reported in the Federal Financial Report to ensure completeness, accuracy and compliance with the required accounting basis. For 1 out of 1 selection, we noted that the Federal ...

U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Condition: For 1 out of 1 selection, we were unable to agree the expenditure details from the general ledger to the amounts reported in the Federal Financial Report to ensure completeness, accuracy and compliance with the required accounting basis. For 1 out of 1 selection, we noted that the Federal Financial Report was not submitted timely. Criteria: In accordance with 2 CFR §200.303, 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. In accordance with 2 CFR 200.302: Financial management. (a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state’s own funds. In addition, the state’s and the other non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Additionally, the grant agreement requires the Federal Financial Report to be submitted no later than 90 days after the period of performance end date through recipient online accounts in the Payment Management System. Cause: The agency could not reconcile information reported in the expenditure report to the state to the underlying records. Finance and the agency use different parameters for running reports and neither department reconciled the other reporting completed. Effect: Expenditures reported to the Federal government could be inaccurate. Questioned Costs: None. Recommendation: We recommend the City establish and implement a process to reconcile reports used by the various departments for external reporting to the City’s internal records to validate compliance with reporting requirements. Additionally, there should be a process to ensure all reports are submitted timely. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.

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