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
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.

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