Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
2024-003 – Cash Management Approval Federal Programs – Research and Development Cluster (Assistance Listing No. 98.001) Federal Agencies - U.S. Agency for International Development Federal Award Year – July 1, 2023 to June 30, 2024 Compliance Requirement – Cash Management Criteria Requirement: Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). The reimbursement payment method is the preferred payment method if (a) the non-federal entity cannot the meet the requirements in 2 CFR section 200.305(b)(1) for advance payment, (b) the federal awarding agency sets a specific condition for use of the reimbursement or (c) if requested by the non-federal entity (2 CFR sections 200.305(b)(3) and 200.208). The reimbursement payment method also may be used on a federal award for construction or for other construction activity as specified in 2 CFR section 200.305(b)(3). Condition Found: For two out of thirty-one samples, the institution did not maintain appropriate documentation to evidence the approval of the drawdown request. This resulted in an ineffective control over the review and approval of cash drawdowns. Cause and Possible Asserted Effect: The grants department had turnover in the current year, which resulted in inconsistent documentation of approvals. Therefore, the institution’s control to review and approve cash drawdowns did not operate consistently to ensure requests for reimbursement were properly approved and evidence of the review was maintained. Identification of Questioned Costs: There are no questioned costs associated with this finding. Sampling: The sample was not intended to be and was not a statistically valid sample. Identification of Repeat Finding: This finding is not a repeat of a finding in the immediately prior year Recommendation: Our recommendation is for management to reinforce and train those individuals in the compliance control ownership role to ensure controls are operating as designed in order to prevent, or detect and correct noncompliance on a timely basis. Specifically, strengthening its processes and documentation requirements around the review and approval of cash drawdown requests. This will help ensure that controls are functioning as intended, thereby preventing or promptly identifying and rectifying instances of noncompliance. Views of Responsible Officials: Management agrees with the findings and recommendations. Through the merger with Old Dominion University, additional controls have been adopted around the processes and controls around the accuracy of the review and approval of cash drawdown requests.
2024-003 – Cash Management Approval Federal Programs – Research and Development Cluster (Assistance Listing No. 98.001) Federal Agencies - U.S. Agency for International Development Federal Award Year – July 1, 2023 to June 30, 2024 Compliance Requirement – Cash Management Criteria Requirement: Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). The reimbursement payment method is the preferred payment method if (a) the non-federal entity cannot the meet the requirements in 2 CFR section 200.305(b)(1) for advance payment, (b) the federal awarding agency sets a specific condition for use of the reimbursement or (c) if requested by the non-federal entity (2 CFR sections 200.305(b)(3) and 200.208). The reimbursement payment method also may be used on a federal award for construction or for other construction activity as specified in 2 CFR section 200.305(b)(3). Condition Found: For two out of thirty-one samples, the institution did not maintain appropriate documentation to evidence the approval of the drawdown request. This resulted in an ineffective control over the review and approval of cash drawdowns. Cause and Possible Asserted Effect: The grants department had turnover in the current year, which resulted in inconsistent documentation of approvals. Therefore, the institution’s control to review and approve cash drawdowns did not operate consistently to ensure requests for reimbursement were properly approved and evidence of the review was maintained. Identification of Questioned Costs: There are no questioned costs associated with this finding. Sampling: The sample was not intended to be and was not a statistically valid sample. Identification of Repeat Finding: This finding is not a repeat of a finding in the immediately prior year Recommendation: Our recommendation is for management to reinforce and train those individuals in the compliance control ownership role to ensure controls are operating as designed in order to prevent, or detect and correct noncompliance on a timely basis. Specifically, strengthening its processes and documentation requirements around the review and approval of cash drawdown requests. This will help ensure that controls are functioning as intended, thereby preventing or promptly identifying and rectifying instances of noncompliance. Views of Responsible Officials: Management agrees with the findings and recommendations. Through the merger with Old Dominion University, additional controls have been adopted around the processes and controls around the accuracy of the review and approval of cash drawdown requests.
2024-003 – Cash Management Approval Federal Programs – Research and Development Cluster (Assistance Listing No. 98.001) Federal Agencies - U.S. Agency for International Development Federal Award Year – July 1, 2023 to June 30, 2024 Compliance Requirement – Cash Management Criteria Requirement: Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). The reimbursement payment method is the preferred payment method if (a) the non-federal entity cannot the meet the requirements in 2 CFR section 200.305(b)(1) for advance payment, (b) the federal awarding agency sets a specific condition for use of the reimbursement or (c) if requested by the non-federal entity (2 CFR sections 200.305(b)(3) and 200.208). The reimbursement payment method also may be used on a federal award for construction or for other construction activity as specified in 2 CFR section 200.305(b)(3). Condition Found: For two out of thirty-one samples, the institution did not maintain appropriate documentation to evidence the approval of the drawdown request. This resulted in an ineffective control over the review and approval of cash drawdowns. Cause and Possible Asserted Effect: The grants department had turnover in the current year, which resulted in inconsistent documentation of approvals. Therefore, the institution’s control to review and approve cash drawdowns did not operate consistently to ensure requests for reimbursement were properly approved and evidence of the review was maintained. Identification of Questioned Costs: There are no questioned costs associated with this finding. Sampling: The sample was not intended to be and was not a statistically valid sample. Identification of Repeat Finding: This finding is not a repeat of a finding in the immediately prior year Recommendation: Our recommendation is for management to reinforce and train those individuals in the compliance control ownership role to ensure controls are operating as designed in order to prevent, or detect and correct noncompliance on a timely basis. Specifically, strengthening its processes and documentation requirements around the review and approval of cash drawdown requests. This will help ensure that controls are functioning as intended, thereby preventing or promptly identifying and rectifying instances of noncompliance. Views of Responsible Officials: Management agrees with the findings and recommendations. Through the merger with Old Dominion University, additional controls have been adopted around the processes and controls around the accuracy of the review and approval of cash drawdown requests.
Condition: The Organization’s written policies and procedures related to financial management and procurement do not meet the requirements of 2 CFR 200, Subpart D and Subpart E. Criteria: According to 2 CFR Section 200.302.b and 2 CFR Section 200.305 of the Uniform Guidance, the Organization is required to have a written financial management policy. Additionally, according to 2 CFR Section 200.317 – 200.326, the Organization is required to have a written procurement policy. Cause: The Organization was unaware of requirements regarding policies and procedures outlined in the Uniform Guidance. Effect: Written policies necessary for non-Federal entities receiving federal funds were not in place. Repeat Finding: Yes Questioned Costs: None reported Recommendation: We recommend that the Organization update their written policies and procedures that meet the requirements of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Views of Responsible Officials and Planned Corrective Action: We concur with the auditor’s finding and will update the Organization’s written policies and procedures for the Uniform Guidance requirements.
Condition: The Organization’s written policies and procedures related to financial management and procurement do not meet the requirements of 2 CFR 200, Subpart D and Subpart E. Criteria: According to 2 CFR Section 200.302.b and 2 CFR Section 200.305 of the Uniform Guidance, the Organization is required to have a written financial management policy. Additionally, according to 2 CFR Section 200.317 – 200.326, the Organization is required to have a written procurement policy. Cause: The Organization was unaware of requirements regarding policies and procedures outlined in the Uniform Guidance. Effect: Written policies necessary for non-Federal entities receiving federal funds were not in place. Repeat Finding: Yes Questioned Costs: None reported Recommendation: We recommend that the Organization update their written policies and procedures that meet the requirements of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Views of Responsible Officials and Planned Corrective Action: We concur with the auditor’s finding and will update the Organization’s written policies and procedures for the Uniform Guidance requirements.
Finding 2024-004: Unallowable Costs / Cash Management (Material Weakness) Information on the Federal Programs: Assistance Listing Number 98.001 Criteria: According to Uniform Guidance (2 CFR 200.305(b)), Federal funds must be managed in a way that minimizes the time elapsing between the transfer of funds and the Organization’s disbursement of those funds for program purposes. Additionally, internal controls over cash management should ensure that all drawdowns are approved by designated personnel to prevent improper or premature use of Federal funds. Furthermore, per 2 CFR 200.414(c), indirect costs may only be charged to a Federal program if an approved indirect cost rate or a direct cost allocation methodology is in place and if the Federal award allows for indirect cost recovery. Condition: During our review of Federal grant drawdowns, it was noted that several drawdowns were processed without obtaining the required internal approvals as outlined in Astraea's cash management policies and procedures. We also noted that several draws included indirect costs, despite the Federal award agreement explicitly prohibiting indirect cost recovery. While these costs were later removed and ultimately not charged to the Federal program, their inclusion initially led to an overdraw of funds exceeding the program’s actual needs. Furthermore, Astraea is carrying a large refundable advance balance. Cause: Astraea’s cash management procedures were not consistently followed, leading to missed approvals for certain drawdowns and delays in fund disbursement. Additionally, the lack of approval led to errors in charging indirect costs to the program.Effect: Drawdowns without proper internal approval increase the risk of non-compliance with Federal cash management requirements and could result in unauthorized or inaccurate fund usage. Additionally, charging unallowable indirect costs to the program resulted in noncompliance with Federal regulations. Furthermore, the delay in disbursing Federal funds increases the risk of noncompliance with cash management requirements, potentially resulting in interest liability. Questioned Costs: None noted. Identification as a Repeat Finding, if Applicable: Finding 2023-005 Recommendation: Astraea should reinforce cash management controls by ensuring all Federal drawdowns obtain the appropriate internal approvals before processing. This can be achieved by implementing a checklist or automated workflow to verify compliance with approval requirements. Astraea should also strengthen internal controls over cost allocation to prevent unallowable indirect charges. Additionally, we recommend Astraea implement procedures to ensure that Federal funds are disbursed promptly in accordance with 2 CFR 200.305 to avoid undue delays.
Finding 2024-001 Payment to fraudulent subrecipient account - cyber incident Repeat Finding No Federal Program Title U.S. Department of Health and Human Services 93.600 Head Start Award # 05CH012065-02-00 Award Year 9/1/2022 – 8/31/2023 Finding In connection with a cyber incident at a subrecipient, Chicago Commons Association (Commons) sent two federal fund payments to a fraudulent party acting as the subrecipient. Criteria 2 CFR 200.305 (b) describes federal payments for recipients and subrecipients other than states, whether the payment is made by electronic funds transfer or by other means. Per 2 CFR 200.516(a), the auditor must report as an audit finding various items including known or likely fraud affecting a federal award. Audit finding detail and clarity is described in the next section, 2 CFR 200.516(b), which requires specific information to be included such as “(3) The condition found, including facts that support the deficiency found in the audit finding.” Condition The design and execution of certain internal controls were not successful in preventing or detecting Commons’ payments to a bank account controlled by a fraudulent party posing as a subrecipient. This resulted from a scheme related to a cyber incident at the subrecipient. Gads Hill Center (GHC), a nonprofit after-school program located in Chicago and a subrecipient/delegate agency of Commons, was victim to a cyber incident whereby a fraudulent party was able to take control of GHC’s email and telephone systems. This fraudulent party then contacted Commons AP manager via email on August 7, 2023, posing as the GHC Chief Financial Officer. Through email communications with the Commons AP manager and VP of Finance, this fraudulent party submitted updated banking/ACH information for GHC to change their ACH information from Fifth Third Bank (the valid GHC bank account) to Truist Bank (the fraudulent party’s bank account). An email was sent from the Commons AP manager to the Commons VP of Finance to have the information updated in the system. Commons’ policies require that a request received for this type of change to be substantiated through a direct phone call to the subrecipient. The Commons AP manager called the GHC CFO (the number used was Pilsen location shown on the GHC website) but the call went unanswered (and voicemail was full). The AP manager and GHC CFO scheduled a call for the next week and the AP manager received a phone call from an identical phone number from an individual who identified himself as the GHC CFO, and completed the verification process. New banking information was then entered and approved in Commons’ primary banking partner’s system (US Bank). These emails and calls happened between August 7 and August 15, 2023. Commons received a voucher from GHC and made a $70,121.99 payment to Truist Bank on August 17, using the updated ACH information. The primary banking partner of Commons flagged this payment as potentially fraudulent because the name on the ACH payment did not match the name listed on the bank account, and contacted Commons. Commons communicated that the banking information was correct, and the payment was then released on August 22. Another GHC-submitted voucher was received, and $640,318.83 was also paid to Truist Bank on August 24, 2023. The payments were not received by GHC. GHC subsequently contacted Commons to follow up about the status of the payments due and through the ensuing discussion the payments to the fraudulent Truist Bank account were ultimately discovered. The two submitted vouchers for expenses incurred by GHC were valid, in connection with program services performed by GHC. Commons reviewed, approved and submitted the two vouchers to the U.S. Department of Health and Human Services (the funder) for reimbursement. The funder approved the expenses, funds were released to Commons and then disbursed by Commons to the Truist Bank account which management believed belonged to GHC. Commons recorded and reported revenue and expense (payment to subrecipient) for the amounts of the vouchers received and paid. Because GHC incurred the expenses but never received the reimbursement funds, GHC absorbed the loss. Cause Commons personnel had followed established processes and internal controls as intended. However, the design and execution of the controls were not successful in preventing or detecting payments to a fraudulent account. Management believes the sophistication of the fraud scheme exceeded the effectiveness of the controls. Effect The change in ACH information resulted in two Commons’ payments of federal funds totaling $710,440.82 made to a bank account controlled by the fraudulent party acting as the subrecipient. Context Chicago Commons made us aware of this matter which appears to be an isolated incident for the year ended June 30, 2024. Questioned Costs There were no known questioned costs. Recommendation We recommend that Commons strengthens its internal controls in verifying a requested bank account change. For example, the procedure can include a requirement for the phone call to be made by an individual at Commons with personal knowledge and familiarity with a specific individual at the organization requesting the change. Views of Responsible Officials Management is in agreement with this finding. See corrective action plan.
Finding No. 2024-081 Federal Awarding Agency: U.S Department of Energy, U.S. Department of Defense, National Aeronautics and Space Administration (NASA), and Department of Commerce Impact: Significant Deficiency, Noncompliance AL Number and Title: 81.049, 12.000, 43.001, 11.417 Research and Development Cluster (RDC) Federal Award Number: N/A Applicable Compliance Requirement: Cash Management Condition: Fifteen of the sampled 40 subrecipient draws, on reimbursement basis, were paid to the subrecipients beyond 30 days of when the University received the payment request. Context: During testing of subrecipient cash management, five grants from University of Alaska Fairbanks (UAF) had fifteen observed instances of individual payments requests from the subrecipient were received by UAF and not disbursed to the subrecipient within the allowable thirty days. Cause: UAF did not process payment requests from the subrecipients timely. Criteria: The federal Government requires that when the reimbursement method is used, the federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per 2 CFR 180.300 nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to do business with are not excluded or disqualified. Effect: Subrecipients on federal awards do not receive timely payment for federal contract work. Questioned Costs: None Recommendation: UAF management should work to develop policies and procedures to allow for more timely payment to subrecipients for work the University contracts them to perform. Views of Responsible Officials: Management agrees with this finding.
Finding No. 2024-081 Federal Awarding Agency: U.S Department of Energy, U.S. Department of Defense, National Aeronautics and Space Administration (NASA), and Department of Commerce Impact: Significant Deficiency, Noncompliance AL Number and Title: 81.049, 12.000, 43.001, 11.417 Research and Development Cluster (RDC) Federal Award Number: N/A Applicable Compliance Requirement: Cash Management Condition: Fifteen of the sampled 40 subrecipient draws, on reimbursement basis, were paid to the subrecipients beyond 30 days of when the University received the payment request. Context: During testing of subrecipient cash management, five grants from University of Alaska Fairbanks (UAF) had fifteen observed instances of individual payments requests from the subrecipient were received by UAF and not disbursed to the subrecipient within the allowable thirty days. Cause: UAF did not process payment requests from the subrecipients timely. Criteria: The federal Government requires that when the reimbursement method is used, the federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per 2 CFR 180.300 nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to do business with are not excluded or disqualified. Effect: Subrecipients on federal awards do not receive timely payment for federal contract work. Questioned Costs: None Recommendation: UAF management should work to develop policies and procedures to allow for more timely payment to subrecipients for work the University contracts them to perform. Views of Responsible Officials: Management agrees with this finding.
Finding No. 2024-081 Federal Awarding Agency: U.S Department of Energy, U.S. Department of Defense, National Aeronautics and Space Administration (NASA), and Department of Commerce Impact: Significant Deficiency, Noncompliance AL Number and Title: 81.049, 12.000, 43.001, 11.417 Research and Development Cluster (RDC) Federal Award Number: N/A Applicable Compliance Requirement: Cash Management Condition: Fifteen of the sampled 40 subrecipient draws, on reimbursement basis, were paid to the subrecipients beyond 30 days of when the University received the payment request. Context: During testing of subrecipient cash management, five grants from University of Alaska Fairbanks (UAF) had fifteen observed instances of individual payments requests from the subrecipient were received by UAF and not disbursed to the subrecipient within the allowable thirty days. Cause: UAF did not process payment requests from the subrecipients timely. Criteria: The federal Government requires that when the reimbursement method is used, the federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per 2 CFR 180.300 nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to do business with are not excluded or disqualified. Effect: Subrecipients on federal awards do not receive timely payment for federal contract work. Questioned Costs: None Recommendation: UAF management should work to develop policies and procedures to allow for more timely payment to subrecipients for work the University contracts them to perform. Views of Responsible Officials: Management agrees with this finding.
Criteria or Specific Requirement: In accordance with 2 CFR 200.305(b), when entities are on a cost reimbursement basis, payments must be requested only for allowable costs already incurred, and such requests should be made in a timely manner to avoid cash flow issues and ensure proper stewardship of federal funds. Condition and Context: During our testing, we determined that Solvista Health incurred allowable expenditures under the federal awards but did not submit claims for reimbursement in a timely manner. Specifically, expenditures were recorded and reported internally, but Solvista Health did not initiate the cost reimbursement requests in accordance with the timing of those expenditures. Questioned Costs: N/A Cause: Solvista Health lacks sufficient oversight or adequate internal controls to ensure timely submission of reimbursement requests corresponding with incurred expenditures. Effect: Failure to request reimbursement in a timely manner can impair cash flow, result in underutilization of available federal funds within the grant period, and indicate noncompliance with requirements under Uniform Guidance. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that Solvista Health implement formal procedures as well as assign an individual responsible for submitting reimbursement requests on a regular and timely basis after expenditures are incurred. This will promote compliance with federal requirements and ensure Solvista Health benefits fully from available federal grant funding.
Criteria or Specific Requirement: In accordance with 2 CFR 200.305(b), when entities are on a cost reimbursement basis, payments must be requested only for allowable costs already incurred, and such requests should be made in a timely manner to avoid cash flow issues and ensure proper stewardship of federal funds. Condition and Context: During our testing, we determined that Solvista Health incurred allowable expenditures under the federal awards but did not submit claims for reimbursement in a timely manner. Specifically, expenditures were recorded and reported internally, but Solvista Health did not initiate the cost reimbursement requests in accordance with the timing of those expenditures. Questioned Costs: N/A Cause: Solvista Health lacks sufficient oversight or adequate internal controls to ensure timely submission of reimbursement requests corresponding with incurred expenditures. Effect: Failure to request reimbursement in a timely manner can impair cash flow, result in underutilization of available federal funds within the grant period, and indicate noncompliance with requirements under Uniform Guidance. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that Solvista Health implement formal procedures as well as assign an individual responsible for submitting reimbursement requests on a regular and timely basis after expenditures are incurred. This will promote compliance with federal requirements and ensure Solvista Health benefits fully from available federal grant funding.
Criteria or Specific Requirement: In accordance with 2 CFR 200.305(b), when entities are on a cost reimbursement basis, payments must be requested only for allowable costs already incurred, and such requests should be made in a timely manner to avoid cash flow issues and ensure proper stewardship of federal funds. Condition and Context: During our testing, we determined that Solvista Health incurred allowable expenditures under the federal awards but did not submit claims for reimbursement in a timely manner. Specifically, expenditures were recorded and reported internally, but Solvista Health did not initiate the cost reimbursement requests in accordance with the timing of those expenditures. Questioned Costs: N/A Cause: Solvista Health lacks sufficient oversight or adequate internal controls to ensure timely submission of reimbursement requests corresponding with incurred expenditures. Effect: Failure to request reimbursement in a timely manner can impair cash flow, result in underutilization of available federal funds within the grant period, and indicate noncompliance with requirements under Uniform Guidance. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that Solvista Health implement formal procedures as well as assign an individual responsible for submitting reimbursement requests on a regular and timely basis after expenditures are incurred. This will promote compliance with federal requirements and ensure Solvista Health benefits fully from available federal grant funding.
Criteria or Specific Requirement: In accordance with 2 CFR 200.305(b), when entities are on a cost reimbursement basis, payments must be requested only for allowable costs already incurred, and such requests should be made in a timely manner to avoid cash flow issues and ensure proper stewardship of federal funds. Condition and Context: During our testing, we determined that Solvista Health incurred allowable expenditures under the federal awards but did not submit claims for reimbursement in a timely manner. Specifically, expenditures were recorded and reported internally, but Solvista Health did not initiate the cost reimbursement requests in accordance with the timing of those expenditures. Questioned Costs: N/A Cause: Solvista Health lacks sufficient oversight or adequate internal controls to ensure timely submission of reimbursement requests corresponding with incurred expenditures. Effect: Failure to request reimbursement in a timely manner can impair cash flow, result in underutilization of available federal funds within the grant period, and indicate noncompliance with requirements under Uniform Guidance. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that Solvista Health implement formal procedures as well as assign an individual responsible for submitting reimbursement requests on a regular and timely basis after expenditures are incurred. This will promote compliance with federal requirements and ensure Solvista Health benefits fully from available federal grant funding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00109-22; H80CS00109-23 Award Period: May 1, 2023 – April 30, 2024; May 1, 2024 – April 30, 2025 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR 200.305(b)(1) requires that recipients of federal funds maintain both written procedures that minimize the time elapsing between the transfer of funds from the Federal agency and the disbursement of funds by the recipient, and financial management systems that meet the standards for fund control and accountability. Furthermore, 2 CFR 200.303 indicates the non-Federal entity must: (a) Establish, document 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). Condition: The Organization did not maintain timely documentation to support an independent review and approval of the drawdowns prior the drawdown occurring. Questioned costs: None Context: This condition occurred in two (2) of six (6) transactions selected for testing. Cause: Turnover in key positions within the finance department. Effect: Drawdowns may occur for the incorrect amount, for the wrong period and for costs that may not have been incurred as of yet. Repeat Finding: No. Recommendation: We recommend management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented with supporting documentation retained for the revised internal control. Views of responsible officials: There is no disagreement with this finding.
Federal Transit Cluster – Cash Management Noncompliance and Significant Deficiency in Internal Control ALN’s 20.507 and 20.526 U.S. Department of Transportation – Federal Transit Administration Criteria: In accordance with 2 CFR § 200.305(b), when advance payments are made, they must be limited to the minimum amounts needed and timed to the actual, immediate cash requirements of the recipient. The Federal Transit Administration (FTA) further clarifies that federal funds drawn in advance must be disbursed within three business days to comply with this requirement. This standard is intended to minimize the time elapsing between the transfer of funds and disbursement. Condition: The Authority drew down federal funds in advance of allowable expenditures and did not disburse the federal funds within the required three business days. Cause: The Authority did not have adequate internal controls in place to ensure that federal funds were drawn only after costs had been incurred or that disbursements occurred within the required timeframe. Effect: As a result of the noncompliance, the Authority was required to repay $251,630 to the FTA. Questioned Costs: $251,630 drawn down in excess of the immediate need. Context: For one drawdown in a sample of seven, the Authority drew down funds to be used for preventative maintenance costs during the month during the preceding month. As a result, the Authority held the funds until there were sufficient qualifying expenditures, which was for a time period in excess of three business days. Recommendation: We recommend that the Authority strengthen its internal controls over cash management to ensure that federal funds are drawn only after expenditures have been incurred or that disbursements are made within three business days of receipt if drawn in advance. Staff should be trained on federal cash management requirements, and drawdown procedures should be reviewed and updated accordingly. Views of Responsible Officials: See Corrective Action Plan
Federal Transit Cluster – Cash Management Noncompliance and Significant Deficiency in Internal Control ALN’s 20.507 and 20.526 U.S. Department of Transportation – Federal Transit Administration Criteria: In accordance with 2 CFR § 200.305(b), when advance payments are made, they must be limited to the minimum amounts needed and timed to the actual, immediate cash requirements of the recipient. The Federal Transit Administration (FTA) further clarifies that federal funds drawn in advance must be disbursed within three business days to comply with this requirement. This standard is intended to minimize the time elapsing between the transfer of funds and disbursement. Condition: The Authority drew down federal funds in advance of allowable expenditures and did not disburse the federal funds within the required three business days. Cause: The Authority did not have adequate internal controls in place to ensure that federal funds were drawn only after costs had been incurred or that disbursements occurred within the required timeframe. Effect: As a result of the noncompliance, the Authority was required to repay $251,630 to the FTA. Questioned Costs: $251,630 drawn down in excess of the immediate need. Context: For one drawdown in a sample of seven, the Authority drew down funds to be used for preventative maintenance costs during the month during the preceding month. As a result, the Authority held the funds until there were sufficient qualifying expenditures, which was for a time period in excess of three business days. Recommendation: We recommend that the Authority strengthen its internal controls over cash management to ensure that federal funds are drawn only after expenditures have been incurred or that disbursements are made within three business days of receipt if drawn in advance. Staff should be trained on federal cash management requirements, and drawdown procedures should be reviewed and updated accordingly. Views of Responsible Officials: See Corrective Action Plan
Federal Transit Cluster – Cash Management Noncompliance and Significant Deficiency in Internal Control ALN’s 20.507 and 20.526 U.S. Department of Transportation – Federal Transit Administration Criteria: In accordance with 2 CFR § 200.305(b), when advance payments are made, they must be limited to the minimum amounts needed and timed to the actual, immediate cash requirements of the recipient. The Federal Transit Administration (FTA) further clarifies that federal funds drawn in advance must be disbursed within three business days to comply with this requirement. This standard is intended to minimize the time elapsing between the transfer of funds and disbursement. Condition: The Authority drew down federal funds in advance of allowable expenditures and did not disburse the federal funds within the required three business days. Cause: The Authority did not have adequate internal controls in place to ensure that federal funds were drawn only after costs had been incurred or that disbursements occurred within the required timeframe. Effect: As a result of the noncompliance, the Authority was required to repay $251,630 to the FTA. Questioned Costs: $251,630 drawn down in excess of the immediate need. Context: For one drawdown in a sample of seven, the Authority drew down funds to be used for preventative maintenance costs during the month during the preceding month. As a result, the Authority held the funds until there were sufficient qualifying expenditures, which was for a time period in excess of three business days. Recommendation: We recommend that the Authority strengthen its internal controls over cash management to ensure that federal funds are drawn only after expenditures have been incurred or that disbursements are made within three business days of receipt if drawn in advance. Staff should be trained on federal cash management requirements, and drawdown procedures should be reviewed and updated accordingly. Views of Responsible Officials: See Corrective Action Plan
Federal Transit Cluster – Cash Management Noncompliance and Significant Deficiency in Internal Control ALN’s 20.507 and 20.526 U.S. Department of Transportation – Federal Transit Administration Criteria: In accordance with 2 CFR § 200.305(b), when advance payments are made, they must be limited to the minimum amounts needed and timed to the actual, immediate cash requirements of the recipient. The Federal Transit Administration (FTA) further clarifies that federal funds drawn in advance must be disbursed within three business days to comply with this requirement. This standard is intended to minimize the time elapsing between the transfer of funds and disbursement. Condition: The Authority drew down federal funds in advance of allowable expenditures and did not disburse the federal funds within the required three business days. Cause: The Authority did not have adequate internal controls in place to ensure that federal funds were drawn only after costs had been incurred or that disbursements occurred within the required timeframe. Effect: As a result of the noncompliance, the Authority was required to repay $251,630 to the FTA. Questioned Costs: $251,630 drawn down in excess of the immediate need. Context: For one drawdown in a sample of seven, the Authority drew down funds to be used for preventative maintenance costs during the month during the preceding month. As a result, the Authority held the funds until there were sufficient qualifying expenditures, which was for a time period in excess of three business days. Recommendation: We recommend that the Authority strengthen its internal controls over cash management to ensure that federal funds are drawn only after expenditures have been incurred or that disbursements are made within three business days of receipt if drawn in advance. Staff should be trained on federal cash management requirements, and drawdown procedures should be reviewed and updated accordingly. Views of Responsible Officials: See Corrective Action Plan
Federal Transit Cluster – Cash Management Noncompliance and Significant Deficiency in Internal Control ALN’s 20.507 and 20.526 U.S. Department of Transportation – Federal Transit Administration Criteria: In accordance with 2 CFR § 200.305(b), when advance payments are made, they must be limited to the minimum amounts needed and timed to the actual, immediate cash requirements of the recipient. The Federal Transit Administration (FTA) further clarifies that federal funds drawn in advance must be disbursed within three business days to comply with this requirement. This standard is intended to minimize the time elapsing between the transfer of funds and disbursement. Condition: The Authority drew down federal funds in advance of allowable expenditures and did not disburse the federal funds within the required three business days. Cause: The Authority did not have adequate internal controls in place to ensure that federal funds were drawn only after costs had been incurred or that disbursements occurred within the required timeframe. Effect: As a result of the noncompliance, the Authority was required to repay $251,630 to the FTA. Questioned Costs: $251,630 drawn down in excess of the immediate need. Context: For one drawdown in a sample of seven, the Authority drew down funds to be used for preventative maintenance costs during the month during the preceding month. As a result, the Authority held the funds until there were sufficient qualifying expenditures, which was for a time period in excess of three business days. Recommendation: We recommend that the Authority strengthen its internal controls over cash management to ensure that federal funds are drawn only after expenditures have been incurred or that disbursements are made within three business days of receipt if drawn in advance. Staff should be trained on federal cash management requirements, and drawdown procedures should be reviewed and updated accordingly. Views of Responsible Officials: See Corrective Action Plan
Federal Transit Cluster – Cash Management Noncompliance and Significant Deficiency in Internal Control ALN’s 20.507 and 20.526 U.S. Department of Transportation – Federal Transit Administration Criteria: In accordance with 2 CFR § 200.305(b), when advance payments are made, they must be limited to the minimum amounts needed and timed to the actual, immediate cash requirements of the recipient. The Federal Transit Administration (FTA) further clarifies that federal funds drawn in advance must be disbursed within three business days to comply with this requirement. This standard is intended to minimize the time elapsing between the transfer of funds and disbursement. Condition: The Authority drew down federal funds in advance of allowable expenditures and did not disburse the federal funds within the required three business days. Cause: The Authority did not have adequate internal controls in place to ensure that federal funds were drawn only after costs had been incurred or that disbursements occurred within the required timeframe. Effect: As a result of the noncompliance, the Authority was required to repay $251,630 to the FTA. Questioned Costs: $251,630 drawn down in excess of the immediate need. Context: For one drawdown in a sample of seven, the Authority drew down funds to be used for preventative maintenance costs during the month during the preceding month. As a result, the Authority held the funds until there were sufficient qualifying expenditures, which was for a time period in excess of three business days. Recommendation: We recommend that the Authority strengthen its internal controls over cash management to ensure that federal funds are drawn only after expenditures have been incurred or that disbursements are made within three business days of receipt if drawn in advance. Staff should be trained on federal cash management requirements, and drawdown procedures should be reviewed and updated accordingly. Views of Responsible Officials: See Corrective Action Plan
Federal Transit Cluster – Cash Management Noncompliance and Significant Deficiency in Internal Control ALN’s 20.507 and 20.526 U.S. Department of Transportation – Federal Transit Administration Criteria: In accordance with 2 CFR § 200.305(b), when advance payments are made, they must be limited to the minimum amounts needed and timed to the actual, immediate cash requirements of the recipient. The Federal Transit Administration (FTA) further clarifies that federal funds drawn in advance must be disbursed within three business days to comply with this requirement. This standard is intended to minimize the time elapsing between the transfer of funds and disbursement. Condition: The Authority drew down federal funds in advance of allowable expenditures and did not disburse the federal funds within the required three business days. Cause: The Authority did not have adequate internal controls in place to ensure that federal funds were drawn only after costs had been incurred or that disbursements occurred within the required timeframe. Effect: As a result of the noncompliance, the Authority was required to repay $251,630 to the FTA. Questioned Costs: $251,630 drawn down in excess of the immediate need. Context: For one drawdown in a sample of seven, the Authority drew down funds to be used for preventative maintenance costs during the month during the preceding month. As a result, the Authority held the funds until there were sufficient qualifying expenditures, which was for a time period in excess of three business days. Recommendation: We recommend that the Authority strengthen its internal controls over cash management to ensure that federal funds are drawn only after expenditures have been incurred or that disbursements are made within three business days of receipt if drawn in advance. Staff should be trained on federal cash management requirements, and drawdown procedures should be reviewed and updated accordingly. Views of Responsible Officials: See Corrective Action Plan
Finding 2024.003: Cash Management - Significant Deficiency Grantor: U.S. Department of Health and Human Services Federal Program Names: Substance Abuse and Mental Health Services Projects of Regional and National Significance Certified Community Behavioral Health Clinic Expansion Grants Federal Assistance Listing Number: 93.243 and 93.696 Federal Award Identification Number and Year: H79SM087223 - 2024, H79SM086969 - 2024 Criteria In accordance with §200.305, federal payment, grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None Context We selected seven drawdowns for testing of cash management relating to these major programs. We noted there was no formal approval or evidence of review for these drawdowns Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials and Planned Corrective Actions Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Finding 2024.003: Cash Management - Significant Deficiency Grantor: U.S. Department of Health and Human Services Federal Program Names: Substance Abuse and Mental Health Services Projects of Regional and National Significance Certified Community Behavioral Health Clinic Expansion Grants Federal Assistance Listing Number: 93.243 and 93.696 Federal Award Identification Number and Year: H79SM087223 - 2024, H79SM086969 - 2024 Criteria In accordance with §200.305, federal payment, grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None Context We selected seven drawdowns for testing of cash management relating to these major programs. We noted there was no formal approval or evidence of review for these drawdowns Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials and Planned Corrective Actions Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Finding 2024.003: Cash Management - Significant Deficiency Grantor: U.S. Department of Health and Human Services Federal Program Names: Substance Abuse and Mental Health Services Projects of Regional and National Significance Certified Community Behavioral Health Clinic Expansion Grants Federal Assistance Listing Number: 93.243 and 93.696 Federal Award Identification Number and Year: H79SM087223 - 2024, H79SM086969 - 2024 Criteria In accordance with §200.305, federal payment, grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None Context We selected seven drawdowns for testing of cash management relating to these major programs. We noted there was no formal approval or evidence of review for these drawdowns Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials and Planned Corrective Actions Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
2024-001 Payment Timing Requirements Criteria: 2 CFR §200.305(b) requires payments methods must minimize the time elapsing between the transfer of funds from the federal agency and the disbursement of funds and that recipients must make timely payments to contractors in accordance with contract provisions. Condition: Instances were identified where subcontractors were not reimbursed in a timely manner. Recommendation: We recommend that the Organization make all necessary efforts to decrease the amount of time that passes between when funds are received and when subcontractors are reimbursed. Views of Responsible Officials and Planned Corrective Actions: HSNY was unable to submit monthly claims for their primary grant due to delays with New York State Office of Temporary and Disability Assistance (OTDA) drafting and approving a contract for the period. While OTDA approved appropriation of the funds to HSNY, without a contract in place, HSNY was unable to submit claims for payment for the period through June 30, 2024 until the contract was approved in May 2025. Changes to the submittal process implemented by OTDA also delayed HSNY’s ability to submit claims for approval. This had a detrimental impact to cash flow as operating costs needed to be paid during this period. With the approval of the contract and efforts being made at OTDA to expedite payment, HSNY’s cash flow position has since improved and reimbursements to subcontractors as of the audit date are being made timely.
Cash Management-Subrecipient Federal Agency: U.S. Federal Government Federal Program Title: Research and Development Cluster Assistance Listing Number: 93.859; 47.074 Federal Award Identification Number and Year: 1R01GM137083 – 2024; 2317969 - 2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(4)). In addition, per the Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Three subrecipient invoices, totaling $29,306, out of 5 tested, totaling $60,038, were not paid within the required 30 days. Questioned costs: None. Cause: Procedures were not in place to ensure subrecipients were paid within 30 days of receipt of the invoices. Effect: Subrecipients did not receive their reimbursement timely. Repeat finding: Yes, 2023-002 Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the Subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Cash Management-Subrecipient Federal Agency: U.S. Federal Government Federal Program Title: Research and Development Cluster Assistance Listing Number: 93.859; 47.074 Federal Award Identification Number and Year: 1R01GM137083 – 2024; 2317969 - 2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(4)). In addition, per the Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Three subrecipient invoices, totaling $29,306, out of 5 tested, totaling $60,038, were not paid within the required 30 days. Questioned costs: None. Cause: Procedures were not in place to ensure subrecipients were paid within 30 days of receipt of the invoices. Effect: Subrecipients did not receive their reimbursement timely. Repeat finding: Yes, 2023-002 Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the Subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
2024-001 EXCESS DRAWDOWN OF FEDERAL FUNDS Federal agency: U.S. Department of Education Federal Program Title & Assistance Listing Number: Extending Equity into the Digital Workforce Projects of Regional and National Significance -84.411B Award Period: 12/15/2021 - 12/15/2025 Type of Finding: Significant Deficiency, Other Non-compliance Compliance Areas: Cash Management, Allowable Costs, and Cost Principles and Reporting Questioned Costs: None Condition During testing of expenditures and manual journal entries for the Extending Equity into the Digital Workforce (EEDW) grant, we identified a duplicate manual journal entry of $129,781. This entry reclassified August and September 2023 General Fund (Fund 27101) expenditures to the EEDW Fund (Fund 25271). While the costs themselves are necessary and reasonable under the grant's objectives, the duplicate entry resulted in the federal fund expenditures being overstated and reimbursed twice, leading to an overdraw of federal funds. The duplicate entry was reversed by the client upon discovery by the auditors. An audit adjustment was made to record the excess cash balance as unearned grant revenue. Additionally, the annual Federal Financial Report for the period ending December 31, 2023, included these expenditures, causing the reported federal disbursements to be overstated by $129,781. Criteria Cash Management: Although 2 CFR 200.305(b)(1) permits the Cooperative to draw funds in advance, the entity utilizes a cost reimbursement approach for Federal funding. This practice ensures that funds are drawn only for immediate cash needs. 2 CFR 200.305(b)(1) Federal payment. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. Cost Principles and Reporting: The application of cost principles is governed by 2 CFR 200.400; specifically (b) the non-Federal entity assumes responsibility for administering Federal funds in a manner consistent with underlying agreements, program objectives, and the terms and conditions of the Federal award. Effect The error resulted in an overstatement of federal revenues and expenditures, leading to excess unearned cash in the fund at year-end and inaccuracies in the financial reports (SF-425) submitted to the federal funding agency. The Cooperative is not in compliance with federal regulations for Cash Management and Cost Principles and Reporting. Cause The allowable expenditures intended to be reclassified from the general fund to the federal fund were processed twice, resulting in a duplicate recording. This error was not detected during regular reconciliations or the financial close and reporting process.
Reference Number: 2024-003 Description: Written Procedures Condition and Criteria: At the beginning of the audit period, the District did not have a Federal Funds Manual in place to document policies and procedures for managing federal awards in compliance 2 CFR 200, Subparts D and E. The Uniform Guidance requires the following written procedures: Written procedures for grant financial management (2 CFR 200.302 and 2 CFR 200.305) Written procurement policy (2 CFR 200.318a) Written procedures for allowable costs (2 CFR 200.403) Written procedures for managing and safeguarding property or equipment acquired with federal funds (2 CFR 200.313) During the course of the audit, the District developed and implemented a Federal Funds Manual to address this deficiency. Cause: There was an administrative oversight of ensuring the District had these written procedures in place. Effect: The absence of a documented Federal Funds Manual increased the risk of noncompliance with federal requirements and ineffective management of federal funds. However, the district’s subsequent implementation of the manual before the audit’s completion reduced this risk. Recommendation: We recommend that the District continue to utilize and periodically review the Federal Funds Manual to ensure it remains comprehensive and up-to-date with changes in federal requirements. Views of Responsible Officials and Corrective Action: See Corrective Action Plan.
Reference Number: 2024-003 Description: Written Procedures Condition and Criteria: At the beginning of the audit period, the District did not have a Federal Funds Manual in place to document policies and procedures for managing federal awards in compliance 2 CFR 200, Subparts D and E. The Uniform Guidance requires the following written procedures: Written procedures for grant financial management (2 CFR 200.302 and 2 CFR 200.305) Written procurement policy (2 CFR 200.318a) Written procedures for allowable costs (2 CFR 200.403) Written procedures for managing and safeguarding property or equipment acquired with federal funds (2 CFR 200.313) During the course of the audit, the District developed and implemented a Federal Funds Manual to address this deficiency. Cause: There was an administrative oversight of ensuring the District had these written procedures in place. Effect: The absence of a documented Federal Funds Manual increased the risk of noncompliance with federal requirements and ineffective management of federal funds. However, the district’s subsequent implementation of the manual before the audit’s completion reduced this risk. Recommendation: We recommend that the District continue to utilize and periodically review the Federal Funds Manual to ensure it remains comprehensive and up-to-date with changes in federal requirements. Views of Responsible Officials and Corrective Action: See Corrective Action Plan.
Reference Number: 2024-003 Description: Written Procedures Condition and Criteria: At the beginning of the audit period, the District did not have a Federal Funds Manual in place to document policies and procedures for managing federal awards in compliance 2 CFR 200, Subparts D and E. The Uniform Guidance requires the following written procedures: Written procedures for grant financial management (2 CFR 200.302 and 2 CFR 200.305) Written procurement policy (2 CFR 200.318a) Written procedures for allowable costs (2 CFR 200.403) Written procedures for managing and safeguarding property or equipment acquired with federal funds (2 CFR 200.313) During the course of the audit, the District developed and implemented a Federal Funds Manual to address this deficiency. Cause: There was an administrative oversight of ensuring the District had these written procedures in place. Effect: The absence of a documented Federal Funds Manual increased the risk of noncompliance with federal requirements and ineffective management of federal funds. However, the district’s subsequent implementation of the manual before the audit’s completion reduced this risk. Recommendation: We recommend that the District continue to utilize and periodically review the Federal Funds Manual to ensure it remains comprehensive and up-to-date with changes in federal requirements. Views of Responsible Officials and Corrective Action: See Corrective Action Plan.
Finding 2024-001 – Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Cluster Assistance Listing Number: 93.224 & 93.527 Federal Award Identification Number: H80CS00725-22-03 & H80CS00725-23-00 Award Periods: June 1, 2023 – May 31, 2024 & June 1, 2024 – May 31, 2025 Criteria: CFR § 200.303 Internal controls states that 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. Furthermore, CFR § 200.305(b) indicates that the non-Federal entity should minimize the time lapsing between the transfer of funds from the Federal agency and the disbursement of funds by the recipient. Condition: The Organization did not maintain documentation to support the performance of its internal control related to the review and approval of a drawdown request. Questioned Costs: None. Context: This condition occurred in one of the five drawdowns selected for testing. Cause: Turnover within the accounting department. Effect: Unauthorized drawdowns could lead to amounts being drawn in excess of the expenses incurred and charged to a federal grant. Repeat Finding: No. Recommendation: We recommend that management reinforce the current internal control over drawdowns and ensure that when turnover happens, the appropriate employee responsibilities are reassigned. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-001 – Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Cluster Assistance Listing Number: 93.224 & 93.527 Federal Award Identification Number: H80CS00725-22-03 & H80CS00725-23-00 Award Periods: June 1, 2023 – May 31, 2024 & June 1, 2024 – May 31, 2025 Criteria: CFR § 200.303 Internal controls states that 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. Furthermore, CFR § 200.305(b) indicates that the non-Federal entity should minimize the time lapsing between the transfer of funds from the Federal agency and the disbursement of funds by the recipient. Condition: The Organization did not maintain documentation to support the performance of its internal control related to the review and approval of a drawdown request. Questioned Costs: None. Context: This condition occurred in one of the five drawdowns selected for testing. Cause: Turnover within the accounting department. Effect: Unauthorized drawdowns could lead to amounts being drawn in excess of the expenses incurred and charged to a federal grant. Repeat Finding: No. Recommendation: We recommend that management reinforce the current internal control over drawdowns and ensure that when turnover happens, the appropriate employee responsibilities are reassigned. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-001 – Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Cluster Assistance Listing Number: 93.224 & 93.527 Federal Award Identification Number: H80CS00725-22-03 & H80CS00725-23-00 Award Periods: June 1, 2023 – May 31, 2024 & June 1, 2024 – May 31, 2025 Criteria: CFR § 200.303 Internal controls states that 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. Furthermore, CFR § 200.305(b) indicates that the non-Federal entity should minimize the time lapsing between the transfer of funds from the Federal agency and the disbursement of funds by the recipient. Condition: The Organization did not maintain documentation to support the performance of its internal control related to the review and approval of a drawdown request. Questioned Costs: None. Context: This condition occurred in one of the five drawdowns selected for testing. Cause: Turnover within the accounting department. Effect: Unauthorized drawdowns could lead to amounts being drawn in excess of the expenses incurred and charged to a federal grant. Repeat Finding: No. Recommendation: We recommend that management reinforce the current internal control over drawdowns and ensure that when turnover happens, the appropriate employee responsibilities are reassigned. Views of Responsible Officials: There is no disagreement with the audit finding.
Criteria: 2 CFR 200.305(b) states for non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Condition: In the current fiscal year, the Council received new federal money to provide teen pregnancy prevention services. In order to carry out those services, the Council enters into sub-awards with providers throughout its service territory. Providers submit their invoices to the Council monthly, and the Council submits a request for payment to the grantor for reimbursement. For services provided in June, the Council submitted the request but did not disburse the funds to the providers timely as to minimize the time between the recipient of the grant funds and the payment to the provider. Questioned Costs: None. Context: The Council provided services under a grant received directly from the U.S. Department of Health and Human Services. In order to provide the services, sub-awards are made with providers within the Council’s service territory. Providers were to be paid based off the invoices submitted to the Council. The Council submits a request for payment to the U.S. Department of Health and Human Services and once the funds are received, the Council is to pay its providers in a timely manner. Cause: Due to the program being new, the Council’s payment process has not been updated appropriately to ensure timely payment each and every month. Effect: The providers were not paid timely for services provided in June of 2024. Repeat Finding: This was not a repeat finding. Recommendation: We recommend updates in the payment process to ensure that all providers are paid timely after receipt of grant funds. Management Response: FHCCP acknowledges the finding and has taken immediate corrective action to ensure this issue does not recur. We have established a streamlined process for timely disbursement of funds to providers upon receipt of grant funds. Additionally, we have conducted a training session for staff involved in the payment process to ensure they are fully aware of the new procedures and timelines. A monitoring system has also been implemented to track the timeliness of payments and address any delays promptly. We are confident that these steps will prevent any future delays in payments to our providers. FHCCP remains committed to maintaining compliance with all grant requirements and ensuring the efficient and effective use of federal funds.