FINDING 2023-005 Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistant Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition and Context The School Corporation did not have effective internal controls in place to ensure that costs charged to the COVID-19 - Education Stabilization Fund (ESF) grant award were allowable and in conformance with the cost principles. The School Corporation designed and implemented a process to ensure that costs charged for vendor claims to the ESF grant award were allowable and in conformance with the cost principles. The process was for vendor claims to be reviewed and approved by the department head and the Treasurer. However, during our test of 40 vendor claims, there were 17 claims that were not approved by the department head and the Treasurer. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place regarding vendor claims. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-005 Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistant Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition and Context The School Corporation did not have effective internal controls in place to ensure that costs charged to the COVID-19 - Education Stabilization Fund (ESF) grant award were allowable and in conformance with the cost principles. The School Corporation designed and implemented a process to ensure that costs charged for vendor claims to the ESF grant award were allowable and in conformance with the cost principles. The process was for vendor claims to be reviewed and approved by the department head and the Treasurer. However, during our test of 40 vendor claims, there were 17 claims that were not approved by the department head and the Treasurer. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place regarding vendor claims. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-005 Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistant Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition and Context The School Corporation did not have effective internal controls in place to ensure that costs charged to the COVID-19 - Education Stabilization Fund (ESF) grant award were allowable and in conformance with the cost principles. The School Corporation designed and implemented a process to ensure that costs charged for vendor claims to the ESF grant award were allowable and in conformance with the cost principles. The process was for vendor claims to be reviewed and approved by the department head and the Treasurer. However, during our test of 40 vendor claims, there were 17 claims that were not approved by the department head and the Treasurer. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place regarding vendor claims. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-005 Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistant Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition and Context The School Corporation did not have effective internal controls in place to ensure that costs charged to the COVID-19 - Education Stabilization Fund (ESF) grant award were allowable and in conformance with the cost principles. The School Corporation designed and implemented a process to ensure that costs charged for vendor claims to the ESF grant award were allowable and in conformance with the cost principles. The process was for vendor claims to be reviewed and approved by the department head and the Treasurer. However, during our test of 40 vendor claims, there were 17 claims that were not approved by the department head and the Treasurer. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place regarding vendor claims. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-005 Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistant Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition and Context The School Corporation did not have effective internal controls in place to ensure that costs charged to the COVID-19 - Education Stabilization Fund (ESF) grant award were allowable and in conformance with the cost principles. The School Corporation designed and implemented a process to ensure that costs charged for vendor claims to the ESF grant award were allowable and in conformance with the cost principles. The process was for vendor claims to be reviewed and approved by the department head and the Treasurer. However, during our test of 40 vendor claims, there were 17 claims that were not approved by the department head and the Treasurer. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place regarding vendor claims. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-005 Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistant Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition and Context The School Corporation did not have effective internal controls in place to ensure that costs charged to the COVID-19 - Education Stabilization Fund (ESF) grant award were allowable and in conformance with the cost principles. The School Corporation designed and implemented a process to ensure that costs charged for vendor claims to the ESF grant award were allowable and in conformance with the cost principles. The process was for vendor claims to be reviewed and approved by the department head and the Treasurer. However, during our test of 40 vendor claims, there were 17 claims that were not approved by the department head and the Treasurer. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place regarding vendor claims. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-006 Subject: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistant Listings Number: 84.425U Federal Award Number and Year (or Other Identifying Number): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Modified Opinion Condition and Context Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to its laborers and mechanics. Nonfederal entities are to include in construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor must comply with these requirements and the DOL regulations. This would include a requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. The School Corporation had established policies and procedures to ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause prior to management signing the contract; however, the School Corporation's policies did not include a system of internal controls to ensure that the required certified payrolls were submitted by the contractors. One construction contract was awarded, totaling $629,800, with payments of $472,180 during the audit period, that was paid from the COVID-19 - Education Stabilization Fund grant award. The contract contained the required prevailing wage rate clause; however, the School Corporation had not obtained the required payroll and statements of compliance related to the contract. The lack of internal controls and noncompliance were isolated to the one contract noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 29 CFR 5.5 states in part: "(a) The Agency head shall cause or require the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part from Federal funds or in accordance with guarantees of a Federal agency or financed from funds obtained by pledge of any contract of a Federal agency to make a loan, grant or annual contribution (except where a different meaning is expressly indicated), and which is subject to the labor standards provisions of any of the acts listed in § 5.1, the following clauses . . . (1) Minimum wages. (i) All laborers and mechanics employed or working upon the site of the work (or under the United States Housing Act of 1937 or under the Housing Act of 1949 in the construction or development of the project), will be paid unconditionally and not less often than once a week, and without subsequent deduction or rebate on any account (except such payroll deductions as are permitted by regulations issued by the Secretary of Labor under the Copeland Act (29 CFR part 3)), the full amount of wages and bona fide fringe benefits (or cash equivalents thereof) due at time of payment computed at rates not less than those contained in the wage determination of the Secretary of Labor which is attached hereto and made a part hereof, regardless of any contractual relationship which may be alleged to exist between the contractor and such laborers and mechanics. . . . (3) Payrolls and basic records. . . . (ii) (A) The contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the (write in name of appropriate federal agency) if the agency is a party to the contract, but if the agency is not such a party, the contractor will submit the payrolls to the applicant, sponsor, or owner, as the case may be, for transmission to the (write in name of agency). The payrolls submitted shall set out accurately and completely all of the information required to be maintained under29 CFR 5.5(a)(3)(i), except that full social security numbers and home addresses shall not be included on weekly transmittals. . . ." 2 CFR 200 Appendix II states in part: "In addition to other provisions required by the Federal agency or non-Federal entity; all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. . . . (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non- Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, 'Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction'). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. . . ." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, certified payrolls were not obtained as required. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure payroll records are obtained as required. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-006 Subject: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistant Listings Number: 84.425U Federal Award Number and Year (or Other Identifying Number): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Modified Opinion Condition and Context Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to its laborers and mechanics. Nonfederal entities are to include in construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor must comply with these requirements and the DOL regulations. This would include a requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. The School Corporation had established policies and procedures to ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause prior to management signing the contract; however, the School Corporation's policies did not include a system of internal controls to ensure that the required certified payrolls were submitted by the contractors. One construction contract was awarded, totaling $629,800, with payments of $472,180 during the audit period, that was paid from the COVID-19 - Education Stabilization Fund grant award. The contract contained the required prevailing wage rate clause; however, the School Corporation had not obtained the required payroll and statements of compliance related to the contract. The lack of internal controls and noncompliance were isolated to the one contract noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 29 CFR 5.5 states in part: "(a) The Agency head shall cause or require the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part from Federal funds or in accordance with guarantees of a Federal agency or financed from funds obtained by pledge of any contract of a Federal agency to make a loan, grant or annual contribution (except where a different meaning is expressly indicated), and which is subject to the labor standards provisions of any of the acts listed in § 5.1, the following clauses . . . (1) Minimum wages. (i) All laborers and mechanics employed or working upon the site of the work (or under the United States Housing Act of 1937 or under the Housing Act of 1949 in the construction or development of the project), will be paid unconditionally and not less often than once a week, and without subsequent deduction or rebate on any account (except such payroll deductions as are permitted by regulations issued by the Secretary of Labor under the Copeland Act (29 CFR part 3)), the full amount of wages and bona fide fringe benefits (or cash equivalents thereof) due at time of payment computed at rates not less than those contained in the wage determination of the Secretary of Labor which is attached hereto and made a part hereof, regardless of any contractual relationship which may be alleged to exist between the contractor and such laborers and mechanics. . . . (3) Payrolls and basic records. . . . (ii) (A) The contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the (write in name of appropriate federal agency) if the agency is a party to the contract, but if the agency is not such a party, the contractor will submit the payrolls to the applicant, sponsor, or owner, as the case may be, for transmission to the (write in name of agency). The payrolls submitted shall set out accurately and completely all of the information required to be maintained under29 CFR 5.5(a)(3)(i), except that full social security numbers and home addresses shall not be included on weekly transmittals. . . ." 2 CFR 200 Appendix II states in part: "In addition to other provisions required by the Federal agency or non-Federal entity; all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. . . . (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non- Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, 'Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction'). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. . . ." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, certified payrolls were not obtained as required. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure payroll records are obtained as required. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-007 Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Modified Opinion Condition and Context The COVID-19 - Education Stabilization Funds (ESF) may be used to purchase equipment. Capital expenditures for general and special purpose equipment purchases are subject to prior approval by the Department of Education (ED) or the pass-through entity. In addition, with prior approval by the ED or the pass-through entity, recipients and subrecipients may use the ESF funds to purchase real property and perform construction or minor remodeling, and for improvements to land, buildings, or equipment that meet the overall purpose of the ESF program, which is "to prevent, prepare for, and respond to" the COVID-19 pandemic. A property record or capital asset listing, which would include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number (FAIN)), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, and use and condition of the property is to be maintained for assets purchased that exceed the School Corporation's capitalization threshold. The School Corporation purchased two servers and completed an HVAC project using Education Stabilization Funds; however, those items were not included on property records that included all the required information. The missing information included a description of the property, source of funding, percentage of federal participation in the project costs, location, and use and condition of the property. In addition, a physical inventory was not completed after the equipment was purchased, nor were any procedures in place to ensure the proper safeguarding and maintenance of the equipment purchased. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.313(d) states in part: ". . . (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. . . ." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, property records were not maintained, physical inventories were not conducted, and safeguarding and maintenance of equipment purchased with the Education Stabilization Funds was not conducted. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure asset records include all necessary information and are added individually, inventories and safeguarding and maintenance of equipment purchased is conducted. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-007 Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Modified Opinion Condition and Context The COVID-19 - Education Stabilization Funds (ESF) may be used to purchase equipment. Capital expenditures for general and special purpose equipment purchases are subject to prior approval by the Department of Education (ED) or the pass-through entity. In addition, with prior approval by the ED or the pass-through entity, recipients and subrecipients may use the ESF funds to purchase real property and perform construction or minor remodeling, and for improvements to land, buildings, or equipment that meet the overall purpose of the ESF program, which is "to prevent, prepare for, and respond to" the COVID-19 pandemic. A property record or capital asset listing, which would include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number (FAIN)), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, and use and condition of the property is to be maintained for assets purchased that exceed the School Corporation's capitalization threshold. The School Corporation purchased two servers and completed an HVAC project using Education Stabilization Funds; however, those items were not included on property records that included all the required information. The missing information included a description of the property, source of funding, percentage of federal participation in the project costs, location, and use and condition of the property. In addition, a physical inventory was not completed after the equipment was purchased, nor were any procedures in place to ensure the proper safeguarding and maintenance of the equipment purchased. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.313(d) states in part: ". . . (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. . . ." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, property records were not maintained, physical inventories were not conducted, and safeguarding and maintenance of equipment purchased with the Education Stabilization Funds was not conducted. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure asset records include all necessary information and are added individually, inventories and safeguarding and maintenance of equipment purchased is conducted. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-007 Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Modified Opinion Condition and Context The COVID-19 - Education Stabilization Funds (ESF) may be used to purchase equipment. Capital expenditures for general and special purpose equipment purchases are subject to prior approval by the Department of Education (ED) or the pass-through entity. In addition, with prior approval by the ED or the pass-through entity, recipients and subrecipients may use the ESF funds to purchase real property and perform construction or minor remodeling, and for improvements to land, buildings, or equipment that meet the overall purpose of the ESF program, which is "to prevent, prepare for, and respond to" the COVID-19 pandemic. A property record or capital asset listing, which would include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number (FAIN)), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, and use and condition of the property is to be maintained for assets purchased that exceed the School Corporation's capitalization threshold. The School Corporation purchased two servers and completed an HVAC project using Education Stabilization Funds; however, those items were not included on property records that included all the required information. The missing information included a description of the property, source of funding, percentage of federal participation in the project costs, location, and use and condition of the property. In addition, a physical inventory was not completed after the equipment was purchased, nor were any procedures in place to ensure the proper safeguarding and maintenance of the equipment purchased. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.313(d) states in part: ". . . (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. . . ." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, property records were not maintained, physical inventories were not conducted, and safeguarding and maintenance of equipment purchased with the Education Stabilization Funds was not conducted. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure asset records include all necessary information and are added individually, inventories and safeguarding and maintenance of equipment purchased is conducted. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-007 Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Modified Opinion Condition and Context The COVID-19 - Education Stabilization Funds (ESF) may be used to purchase equipment. Capital expenditures for general and special purpose equipment purchases are subject to prior approval by the Department of Education (ED) or the pass-through entity. In addition, with prior approval by the ED or the pass-through entity, recipients and subrecipients may use the ESF funds to purchase real property and perform construction or minor remodeling, and for improvements to land, buildings, or equipment that meet the overall purpose of the ESF program, which is "to prevent, prepare for, and respond to" the COVID-19 pandemic. A property record or capital asset listing, which would include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number (FAIN)), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, and use and condition of the property is to be maintained for assets purchased that exceed the School Corporation's capitalization threshold. The School Corporation purchased two servers and completed an HVAC project using Education Stabilization Funds; however, those items were not included on property records that included all the required information. The missing information included a description of the property, source of funding, percentage of federal participation in the project costs, location, and use and condition of the property. In addition, a physical inventory was not completed after the equipment was purchased, nor were any procedures in place to ensure the proper safeguarding and maintenance of the equipment purchased. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.313(d) states in part: ". . . (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. . . ." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, property records were not maintained, physical inventories were not conducted, and safeguarding and maintenance of equipment purchased with the Education Stabilization Funds was not conducted. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure asset records include all necessary information and are added individually, inventories and safeguarding and maintenance of equipment purchased is conducted. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-007 Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Modified Opinion Condition and Context The COVID-19 - Education Stabilization Funds (ESF) may be used to purchase equipment. Capital expenditures for general and special purpose equipment purchases are subject to prior approval by the Department of Education (ED) or the pass-through entity. In addition, with prior approval by the ED or the pass-through entity, recipients and subrecipients may use the ESF funds to purchase real property and perform construction or minor remodeling, and for improvements to land, buildings, or equipment that meet the overall purpose of the ESF program, which is "to prevent, prepare for, and respond to" the COVID-19 pandemic. A property record or capital asset listing, which would include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number (FAIN)), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, and use and condition of the property is to be maintained for assets purchased that exceed the School Corporation's capitalization threshold. The School Corporation purchased two servers and completed an HVAC project using Education Stabilization Funds; however, those items were not included on property records that included all the required information. The missing information included a description of the property, source of funding, percentage of federal participation in the project costs, location, and use and condition of the property. In addition, a physical inventory was not completed after the equipment was purchased, nor were any procedures in place to ensure the proper safeguarding and maintenance of the equipment purchased. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.313(d) states in part: ". . . (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. . . ." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, property records were not maintained, physical inventories were not conducted, and safeguarding and maintenance of equipment purchased with the Education Stabilization Funds was not conducted. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure asset records include all necessary information and are added individually, inventories and safeguarding and maintenance of equipment purchased is conducted. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-007 Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Modified Opinion Condition and Context The COVID-19 - Education Stabilization Funds (ESF) may be used to purchase equipment. Capital expenditures for general and special purpose equipment purchases are subject to prior approval by the Department of Education (ED) or the pass-through entity. In addition, with prior approval by the ED or the pass-through entity, recipients and subrecipients may use the ESF funds to purchase real property and perform construction or minor remodeling, and for improvements to land, buildings, or equipment that meet the overall purpose of the ESF program, which is "to prevent, prepare for, and respond to" the COVID-19 pandemic. A property record or capital asset listing, which would include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number (FAIN)), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, and use and condition of the property is to be maintained for assets purchased that exceed the School Corporation's capitalization threshold. The School Corporation purchased two servers and completed an HVAC project using Education Stabilization Funds; however, those items were not included on property records that included all the required information. The missing information included a description of the property, source of funding, percentage of federal participation in the project costs, location, and use and condition of the property. In addition, a physical inventory was not completed after the equipment was purchased, nor were any procedures in place to ensure the proper safeguarding and maintenance of the equipment purchased. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.313(d) states in part: ". . . (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. . . ." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, property records were not maintained, physical inventories were not conducted, and safeguarding and maintenance of equipment purchased with the Education Stabilization Funds was not conducted. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure asset records include all necessary information and are added individually, inventories and safeguarding and maintenance of equipment purchased is conducted. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-008 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were compiled, prepared, and submitted by one employee without an oversight or review process in place to prevent, or detect and correct, errors. In addition, the six reports submitted during the audit period contained errors. The errors were as follows: The ESSER I, Year 2 and ESSER II, Year 1 reports did not contain any expenditures for the reporting period; however, according to the School Corporation's records, there were expenditures of $43,786 for ESSER I and $39,648 for ESSER II during this period. The ESSER I, Year 3; ESSER II, Year 2; ESSER III, Year 1; and ESSER III, Year 2 reports were not supported by the School Corporation's records, were not accurate and complete, and were not mathematically accurate. Reported amounts were greater than the amount shown in the ledger by $35,940, $97,761, and $25,763, respectively. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, ESSER reports were not supported by the School Corporation's records, were not accurate and complete, and were not mathematically accurate. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all reports are submitted accurately. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-008 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were compiled, prepared, and submitted by one employee without an oversight or review process in place to prevent, or detect and correct, errors. In addition, the six reports submitted during the audit period contained errors. The errors were as follows: The ESSER I, Year 2 and ESSER II, Year 1 reports did not contain any expenditures for the reporting period; however, according to the School Corporation's records, there were expenditures of $43,786 for ESSER I and $39,648 for ESSER II during this period. The ESSER I, Year 3; ESSER II, Year 2; ESSER III, Year 1; and ESSER III, Year 2 reports were not supported by the School Corporation's records, were not accurate and complete, and were not mathematically accurate. Reported amounts were greater than the amount shown in the ledger by $35,940, $97,761, and $25,763, respectively. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, ESSER reports were not supported by the School Corporation's records, were not accurate and complete, and were not mathematically accurate. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all reports are submitted accurately. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-008 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were compiled, prepared, and submitted by one employee without an oversight or review process in place to prevent, or detect and correct, errors. In addition, the six reports submitted during the audit period contained errors. The errors were as follows: The ESSER I, Year 2 and ESSER II, Year 1 reports did not contain any expenditures for the reporting period; however, according to the School Corporation's records, there were expenditures of $43,786 for ESSER I and $39,648 for ESSER II during this period. The ESSER I, Year 3; ESSER II, Year 2; ESSER III, Year 1; and ESSER III, Year 2 reports were not supported by the School Corporation's records, were not accurate and complete, and were not mathematically accurate. Reported amounts were greater than the amount shown in the ledger by $35,940, $97,761, and $25,763, respectively. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, ESSER reports were not supported by the School Corporation's records, were not accurate and complete, and were not mathematically accurate. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all reports are submitted accurately. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-008 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were compiled, prepared, and submitted by one employee without an oversight or review process in place to prevent, or detect and correct, errors. In addition, the six reports submitted during the audit period contained errors. The errors were as follows: The ESSER I, Year 2 and ESSER II, Year 1 reports did not contain any expenditures for the reporting period; however, according to the School Corporation's records, there were expenditures of $43,786 for ESSER I and $39,648 for ESSER II during this period. The ESSER I, Year 3; ESSER II, Year 2; ESSER III, Year 1; and ESSER III, Year 2 reports were not supported by the School Corporation's records, were not accurate and complete, and were not mathematically accurate. Reported amounts were greater than the amount shown in the ledger by $35,940, $97,761, and $25,763, respectively. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, ESSER reports were not supported by the School Corporation's records, were not accurate and complete, and were not mathematically accurate. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all reports are submitted accurately. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-008 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were compiled, prepared, and submitted by one employee without an oversight or review process in place to prevent, or detect and correct, errors. In addition, the six reports submitted during the audit period contained errors. The errors were as follows: The ESSER I, Year 2 and ESSER II, Year 1 reports did not contain any expenditures for the reporting period; however, according to the School Corporation's records, there were expenditures of $43,786 for ESSER I and $39,648 for ESSER II during this period. The ESSER I, Year 3; ESSER II, Year 2; ESSER III, Year 1; and ESSER III, Year 2 reports were not supported by the School Corporation's records, were not accurate and complete, and were not mathematically accurate. Reported amounts were greater than the amount shown in the ledger by $35,940, $97,761, and $25,763, respectively. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, ESSER reports were not supported by the School Corporation's records, were not accurate and complete, and were not mathematically accurate. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all reports are submitted accurately. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-008 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were compiled, prepared, and submitted by one employee without an oversight or review process in place to prevent, or detect and correct, errors. In addition, the six reports submitted during the audit period contained errors. The errors were as follows: The ESSER I, Year 2 and ESSER II, Year 1 reports did not contain any expenditures for the reporting period; however, according to the School Corporation's records, there were expenditures of $43,786 for ESSER I and $39,648 for ESSER II during this period. The ESSER I, Year 3; ESSER II, Year 2; ESSER III, Year 1; and ESSER III, Year 2 reports were not supported by the School Corporation's records, were not accurate and complete, and were not mathematically accurate. Reported amounts were greater than the amount shown in the ledger by $35,940, $97,761, and $25,763, respectively. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, ESSER reports were not supported by the School Corporation's records, were not accurate and complete, and were not mathematically accurate. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all reports are submitted accurately. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-004 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 21-22, FY 22-23, 7182022IN890342, 7182023IN890342 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Procurement The School Corporation did not have effective internal controls in place to ensure costs charged for goods and services to the food service program were properly procured. The School Corporation designed and implemented a process to ensure that costs charged for goods and services to the food service program were properly procured. The process was for vendor claims to be reviewed and approved by the department head or Food Service Director and the Treasurer. However, during our test of 11 vendor claims that fell within the micropurchase threshold, there were 5 claims that were not approved by the department head or the Food Service Director. The lack of internal controls was isolated to 2022-2023. Suspension and Debarment The School Corporation had not properly designed or implemented a system of internal controls which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting noncompliance. Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. Upon inquiry of the School Corporation in order to review the procedures in place for verifying that a vendor with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the School Corporation disclosed procedures had not been performed that ensured all vendors were not suspended or debarred prior to entering into covered transaction. There were five covered transactions that equaled or exceeded $25,000 that were identified, totaling $254,729. All five covered transactions were selected for testing. For two of the transactions, totaling $85,616, the School Corporation had not performed procedures that ensured vendors were not suspended or debarred, or otherwise excluded or disqualified from participating in federal assistance programs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's managements statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, vendors to whom payments equal to or in excess of $25,000 were not verified to be not suspended, debarred, or otherwise excluded. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions or the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that contractors are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-004 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 21-22, FY 22-23, 7182022IN890342, 7182023IN890342 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Procurement The School Corporation did not have effective internal controls in place to ensure costs charged for goods and services to the food service program were properly procured. The School Corporation designed and implemented a process to ensure that costs charged for goods and services to the food service program were properly procured. The process was for vendor claims to be reviewed and approved by the department head or Food Service Director and the Treasurer. However, during our test of 11 vendor claims that fell within the micropurchase threshold, there were 5 claims that were not approved by the department head or the Food Service Director. The lack of internal controls was isolated to 2022-2023. Suspension and Debarment The School Corporation had not properly designed or implemented a system of internal controls which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting noncompliance. Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. Upon inquiry of the School Corporation in order to review the procedures in place for verifying that a vendor with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the School Corporation disclosed procedures had not been performed that ensured all vendors were not suspended or debarred prior to entering into covered transaction. There were five covered transactions that equaled or exceeded $25,000 that were identified, totaling $254,729. All five covered transactions were selected for testing. For two of the transactions, totaling $85,616, the School Corporation had not performed procedures that ensured vendors were not suspended or debarred, or otherwise excluded or disqualified from participating in federal assistance programs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's managements statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, vendors to whom payments equal to or in excess of $25,000 were not verified to be not suspended, debarred, or otherwise excluded. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions or the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that contractors are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-004 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 21-22, FY 22-23, 7182022IN890342, 7182023IN890342 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Procurement The School Corporation did not have effective internal controls in place to ensure costs charged for goods and services to the food service program were properly procured. The School Corporation designed and implemented a process to ensure that costs charged for goods and services to the food service program were properly procured. The process was for vendor claims to be reviewed and approved by the department head or Food Service Director and the Treasurer. However, during our test of 11 vendor claims that fell within the micropurchase threshold, there were 5 claims that were not approved by the department head or the Food Service Director. The lack of internal controls was isolated to 2022-2023. Suspension and Debarment The School Corporation had not properly designed or implemented a system of internal controls which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting noncompliance. Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. Upon inquiry of the School Corporation in order to review the procedures in place for verifying that a vendor with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the School Corporation disclosed procedures had not been performed that ensured all vendors were not suspended or debarred prior to entering into covered transaction. There were five covered transactions that equaled or exceeded $25,000 that were identified, totaling $254,729. All five covered transactions were selected for testing. For two of the transactions, totaling $85,616, the School Corporation had not performed procedures that ensured vendors were not suspended or debarred, or otherwise excluded or disqualified from participating in federal assistance programs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's managements statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, vendors to whom payments equal to or in excess of $25,000 were not verified to be not suspended, debarred, or otherwise excluded. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions or the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that contractors are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.