2 CFR 200 § 200.303

Findings Citing § 200.303

Internal controls.

Total Findings
99,113
Across all audits in database
Showing Page
309 of 1983
50 findings per page
About this section
Section 200.303 requires recipients and subrecipients of Federal awards to establish and maintain effective internal controls to ensure compliance with Federal laws and award conditions. This section affects organizations receiving Federal funding, mandating them to monitor compliance, address noncompliance promptly, and protect sensitive information.
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FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

FY End: 2024-06-30
The Pennsylvania State University
Compliance Requirement: B
Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing...

Assistance Listing, Federal Agency, and Program Name - R&D Cluster - all awards Federal Award Identification Number and Year - R&D Cluster - see SEFA for details Pass-through Entity - R&D Cluster - see SEFA for details Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - No unallowable costs were identified related to the testing completed. Context - The breakdown in controls was identified by management. There were several grants within the R&D Cluster that did not have effort certifications, which are typically performed through a workflow, completed during the year. Cause and Effect - The University’s control was ineffective as it allowed effort certifications to remain outstanding with no detective control to ensure that the certifications were completed timely, resulting in numerous effort certifications that were completed well after a time that would be effective for identifying any adjustments to federal payroll expenditures that would need to be made. As a result, effort certifications were not completed timely. Recommendation - We recommend implementing a control to ensure that all effort certifications are completed within an effective timeframe. Views of Responsible Officials and Planned Corrective Actions - Penn State concurs with the audit finding. Penn State has maintained a compliant effort certification system for decades. Our leadership remains wholly committed to addressing the concerns that were brought to our attention last fall. The FY24 annual effort certification process was launched on July 25, 2024. All business areas were informed at that time that effort confirmation is a “critical financial responsibility” and that final approvals were to be secured by September 30, 2024. It was brought to leadership’s attention that several effort reports were not timely certified. This was investigated by our Research Accounting Office in accordance with Penn State’s policy. As a result of frequent follow up, by the end of October 2024, virtually all such effort reports were resolved. A small number of such effort reports were certified later in fall 2024, generally due to system errors and/or special challenges associated with personnel changes.

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