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)(3)). Per 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: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No 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.
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)(3)). Per 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: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No 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.
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)(3)). Per 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: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No 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.
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)(3)). Per 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: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No 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.
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)(3)). Per 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: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No 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.
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)(3)). Per 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: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No 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.
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)(3)). Per 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: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No 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.
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)(3)). Per 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: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No 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.
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)(3)). Per 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: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No 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.
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)(3)). Per 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: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No 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.
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)(3)). Per 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: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No 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.
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)(3)). Per 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: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No 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.
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)(3)). Per 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: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No 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.
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)(3)). Per 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: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No 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.
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)(3)). Per 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: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No 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.
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)(3)). Per 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: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No 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.
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)(3)). Per 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: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No 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.
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)(3)). Per 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: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No 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.
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)(3)). Per 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: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No 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.
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)(3)). Per 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: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No 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.
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)(3)). Per 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: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No 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.
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)(3)). Per 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: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No 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.
2023-005 – HEERF lack of compliance at one campus - (Significant deficiency) Cluster: Not applicable Sponsoring Agency: Department of Education (ED) Award Names: COVID-19 Education Stabilization Fund Award Numbers: P425E200430 and P425F201596 Assistance Listing Titles: COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and Institutional Aid Portion Assistance Listing Numbers: 84.425E and 84.425F Award Year: 2022-2023 Pass-through entity: Not applicable Criteria 2 CFR 200.303 Internal Controls - The non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The OMB Uniform Guidance Compliance Supplement further notes that: Policies, procedures should provide for segregation of duties within and among processes and controls. For CRRSAA HEERF II and ARP HEERF III, the Certification and Agreement and/or Supplemental Agreement indicate that Student Aid (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from ED’s grant management system (G5), while Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within three calendar days of the drawdown from G5. Regarding HEERF reporting, the Certification and Agreements notes that recipients must promptly and timely provide a detailed accounting of the use of funds provided by this award in such manner and with such subsequent frequency as the Secretary may require. 2 CFR 200.305(b)(9) - Interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS) through an electronic medium using either Automated Clearing House (ACH) network or a Fedwire Funds Service payment. Condition Through our testing of the HEERF student portion at one campus, we noted the following issues related to various compliance requirements: • Cash management - During the COVID-19 pandemic state of emergency, the Student Financial Aid HEERF draws at the campus were made based on anticipated student aid disbursements rather than actual disbursements. Based on our understanding of management’s drawdown process, we noted that in 2020, $237,699 more was drawn down than was awarded to students and in 2022, $7,262,247 more was drawn down at fiscal year-end than was awarded to students. The excess funds were awarded to students during FY2023; however, these awards were all made long after the required15 calendar days from the date of the drawdown, with many of these disbursements not occurring until the Spring 2023 semester. Additionally, as a result of having excess federal cash on hand, an interest calculation should have been completed to determine the amount of interest due back to the federal government and any amount due remitted to the government. The amount of interest that should have been remitted is estimated to be approximately $173,000. • Eligibility - There were no controls identified that could be tested relative to awarding funds to students. A policy was implemented explaining how HEERF funds were to be awarded to students under each tranche of HEERF and no exceptions were noted relative to this policy through our FY2023 detailed testing; however, there were no secondary reviews documented to validate the amounts being awarded to students were complete and accurate and consistent with the policy. • Reporting - We selected the March 31, 2023 and June 30, 2023 quarterly HEERF reports for testing and we were unable to obtain support in an auditable format to agree the student information in question 2(b) within these reports to underlying detail. Additionally, through our review of support in the June 30, 2023 report, in question 3(b) for the following sub-question: “Purchasing, leasing, or renting additional equipment or software to enable distance learning, or upgrading campus wi-fi access or extending open networks to parking lots or public spaces, etc.” it was noted $127,450 was allocated to this purpose. Through review of the underlying detail, we noted $19,250 related to paying 50% of a subscription renewal for the period March 31, 2023 through March 31, 2024. Three of the six months paid at this time towards the subscription, totaling $9,625 are outside of the period of performance and should not have been charged to HEERF. Cause We understand the campus had turnover during FY2021 and FY2022 and as such, individuals managing the cash management aspect of the program were not familiar with the HEERF guidelines. As it pertains to the student eligibility controls, the financial aid office at this campus is small and with a detailed awarding policy, system reports tailored to identify eligible students and an urgency to get out funds to students in need, they did not believe a second review of the student awards was necessary. In terms of the quarterly reports, support was not retained to support how the numbers in the reports selected were generated and it was unable to be reproduced in an auditable format. Finally, regarding the invoice that should not have been charged to HEERF, 50% of the subscription for the period March 31, 2023-March 31, 2024 was paid in FY2023 and when compiling HEERF eligible costs the period this invoice pertained to was not considered. Effect Lack of controls specific to cash management can lead to not managing federal cash appropriately, including incurring interest that was not remitted. The lack of eligibility reviews could lead to students being incorrectly awarded and lack of support for reports submitted could result in the information within the reports not being complete and accurate. Questioned Costs $173,000 in interest that should have been remitted to the federal government for draw downs in advance and $9,625 for costs related to a period outside of the period of performance. Recommendation While the campus spent the remainder of its HEERF funding as of June 30, 2023, we recommend policies and procedures be reviewed related to administering an “ad hoc” emergency financial aid program to the extent one were to arise in the future. Additionally, the campus should revisit controls around the student aid awarding process more broadly and determine if there are any gaps relevant to these observations. Regarding the reporting, we recommend management recreate support for the quarterly reports in an auditable format to the extent they need to be reproduced for the Department of Education and/or for other audit purposes and enhance their policies and procedures around support required when submitting federal or other required reports. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
2023-005 – HEERF lack of compliance at one campus - (Significant deficiency) Cluster: Not applicable Sponsoring Agency: Department of Education (ED) Award Names: COVID-19 Education Stabilization Fund Award Numbers: P425E200430 and P425F201596 Assistance Listing Titles: COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and Institutional Aid Portion Assistance Listing Numbers: 84.425E and 84.425F Award Year: 2022-2023 Pass-through entity: Not applicable Criteria 2 CFR 200.303 Internal Controls - The non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The OMB Uniform Guidance Compliance Supplement further notes that: Policies, procedures should provide for segregation of duties within and among processes and controls. For CRRSAA HEERF II and ARP HEERF III, the Certification and Agreement and/or Supplemental Agreement indicate that Student Aid (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from ED’s grant management system (G5), while Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within three calendar days of the drawdown from G5. Regarding HEERF reporting, the Certification and Agreements notes that recipients must promptly and timely provide a detailed accounting of the use of funds provided by this award in such manner and with such subsequent frequency as the Secretary may require. 2 CFR 200.305(b)(9) - Interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS) through an electronic medium using either Automated Clearing House (ACH) network or a Fedwire Funds Service payment. Condition Through our testing of the HEERF student portion at one campus, we noted the following issues related to various compliance requirements: • Cash management - During the COVID-19 pandemic state of emergency, the Student Financial Aid HEERF draws at the campus were made based on anticipated student aid disbursements rather than actual disbursements. Based on our understanding of management’s drawdown process, we noted that in 2020, $237,699 more was drawn down than was awarded to students and in 2022, $7,262,247 more was drawn down at fiscal year-end than was awarded to students. The excess funds were awarded to students during FY2023; however, these awards were all made long after the required15 calendar days from the date of the drawdown, with many of these disbursements not occurring until the Spring 2023 semester. Additionally, as a result of having excess federal cash on hand, an interest calculation should have been completed to determine the amount of interest due back to the federal government and any amount due remitted to the government. The amount of interest that should have been remitted is estimated to be approximately $173,000. • Eligibility - There were no controls identified that could be tested relative to awarding funds to students. A policy was implemented explaining how HEERF funds were to be awarded to students under each tranche of HEERF and no exceptions were noted relative to this policy through our FY2023 detailed testing; however, there were no secondary reviews documented to validate the amounts being awarded to students were complete and accurate and consistent with the policy. • Reporting - We selected the March 31, 2023 and June 30, 2023 quarterly HEERF reports for testing and we were unable to obtain support in an auditable format to agree the student information in question 2(b) within these reports to underlying detail. Additionally, through our review of support in the June 30, 2023 report, in question 3(b) for the following sub-question: “Purchasing, leasing, or renting additional equipment or software to enable distance learning, or upgrading campus wi-fi access or extending open networks to parking lots or public spaces, etc.” it was noted $127,450 was allocated to this purpose. Through review of the underlying detail, we noted $19,250 related to paying 50% of a subscription renewal for the period March 31, 2023 through March 31, 2024. Three of the six months paid at this time towards the subscription, totaling $9,625 are outside of the period of performance and should not have been charged to HEERF. Cause We understand the campus had turnover during FY2021 and FY2022 and as such, individuals managing the cash management aspect of the program were not familiar with the HEERF guidelines. As it pertains to the student eligibility controls, the financial aid office at this campus is small and with a detailed awarding policy, system reports tailored to identify eligible students and an urgency to get out funds to students in need, they did not believe a second review of the student awards was necessary. In terms of the quarterly reports, support was not retained to support how the numbers in the reports selected were generated and it was unable to be reproduced in an auditable format. Finally, regarding the invoice that should not have been charged to HEERF, 50% of the subscription for the period March 31, 2023-March 31, 2024 was paid in FY2023 and when compiling HEERF eligible costs the period this invoice pertained to was not considered. Effect Lack of controls specific to cash management can lead to not managing federal cash appropriately, including incurring interest that was not remitted. The lack of eligibility reviews could lead to students being incorrectly awarded and lack of support for reports submitted could result in the information within the reports not being complete and accurate. Questioned Costs $173,000 in interest that should have been remitted to the federal government for draw downs in advance and $9,625 for costs related to a period outside of the period of performance. Recommendation While the campus spent the remainder of its HEERF funding as of June 30, 2023, we recommend policies and procedures be reviewed related to administering an “ad hoc” emergency financial aid program to the extent one were to arise in the future. Additionally, the campus should revisit controls around the student aid awarding process more broadly and determine if there are any gaps relevant to these observations. Regarding the reporting, we recommend management recreate support for the quarterly reports in an auditable format to the extent they need to be reproduced for the Department of Education and/or for other audit purposes and enhance their policies and procedures around support required when submitting federal or other required reports. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.
2023-002 - Significant Deficiency - Coronavirus State & Local Fiscal Recovery Funds - Lack of Written Policies and Procedures including Suspension & Debarment and Conflict of Interest Federal Expenditures Compliance Requirement: Procurement and Written Policies ALN Number: 21.027 Criteria: Title 2 of the U.S. Code of Federal Regulations (CFR) 180.300 (January 1, 2021) requires non-federal entities to verify an entity is not excluded or disqualified prior to entering into a covered transaction by, "(a) Checking SAM Exclusions; or (b) Collecting a certification from that [entity]; or (c) Adding a clause or condition to the covered transaction with that [entity]." A good internal control plan requires adequate procedures to ensure the County has proper procedures in place to verify that contractors paid with grant funds are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities. The Uniform Guidance requires nonfederal entities that receive federal awards to establish written policies, procedures, and or/standards of conduct, except if excluded in compliance supplement. There are four basic reasons for creating an internal control system through defining and documenting processes with well-written policies and procedures: 1. Compliance 2. Operational Needs 2. Managing Risks 4. Continuous Improvement Complying with laws and regulations should be a critical funciton of the County. Well-defined and documented processes (i.e. procedures, training manuals) along with records that demonstrate process capability can make evident an effective internal control system and compliance to Federal guidelines. Another important role of documentation of procedures is to ensure processes fundamental to the County are properly guided by County's officials, and are consistent way that meets the County's needs, and that are important related information and data are captured and communicated. Documentation of procedures are important for controlling process, documenting the standard work that was performed and training new employees. Condition: The County lacks certain written policies and procedures required by Uniform Guidance. Although the County has an outdated Accounting Policy, certain policies for Federal Expenditures need to be updated and added. These include: 1. Financial management (200.302) 2. Payment (200.305) 3. General procurement standards (200.318) 4. Competition (200.319) 5. Methods of procurement to be followed (200.320) 6. Compensation - personal services (200.430) 7. Compensation - fringe benefits (200.431) 8. Relocation costs of employees (200.464) 9. Travel costs (200.474) Cause: Appears to be the result of a lack of training coupled with limited staffing and resources. Questioned Costs: None Context for Calculation of Questioned Costs: None Effect: Without adequate procedures to ensure contractors are not suspended, debarred or otherwise excluded from or ineligible for participation in Federal programs or activities, there is an increased risk for the misuse of Federal funds and noncompliance with Federal regulations. Recommendation: We recommend the County implement proceduresto ensure, prior to entering into a covered transaction, that a contractor in not syspended, bebarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and that procedures is adequately documented. Furthermore, the County should familiarize themselves with the Uniform Guidance and implement the following: 1. Develop and document all of its significant processes over federal awards. 2. Make the written policies and procedures available to all personnel and departments within the County. 3. Ensure the written policies and procedures are accurate, complete, and current at all times (The Board of County Commissioners should update the policy on an annual basis.) 4. Revise policies and procedures for changes in business processes and policies over federal awards. 5. Communicate significant changes to all affected personnel immediately to ensure they are aware of any revisions to their responsibilities to the federal award. 6. Document policies and procedures to facilitate training and provide guidelines relative to federal awards for changes in personnel.
Statement of condition: For the Provider Relief Funds, there were no written policies and procedures. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) 200.302 (b)(6) and (7) states that the non-federal entity must establish written procedures to implement the requirements of 2 CFR 200.305 and written procedures for determining the allowability of costs in accordance with 2 CFR 200 Subpart E as well as terms and conditions of the Federal award. Cause of condition: No controls to establish written policies and procedures when Federal awards are received. Effect of condition: During testing, it was noted that there were no written policies and procedures regarding the Federal award. Context: Policies and procedures were verbally communicated or written during fieldwork to assist with testing. Recommendation: To establish written policies and procedures for Federal awards. Views of responsibile officials and planned corrective actions: Management agrees with this finding and will write policies and procedures for Federal awards.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 47.041, National Science Foundation, Engineering Grants - 93.855, U.S. Department of Health and Human Services, Allergy, Immunology and Transplantation Research - 12.910, U.S. Department of Interior, Research and Technology Development (R & D) - 12.431, U.S. Department of Defense, Basic Scientific Research Federal Award Identification Number and Year - 47.041 - 1855937-CBET - 93.855 - 5R01AI158220-02 - 12.910 - D18AC00024 - 12.431 - W52P1J-22-9-3009; W52P1J-20-9-3009-10 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a 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. Condition - The University did not have adequate controls in place to ensure invoices to subrecipients were paid timely within the 30-calendar-day requirement. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - There were no questioned costs identified. Context - Out of 60 payments to subrecipients that were tested related to the R&D Cluster, 8 were made after the 30-calendar-day requirement. In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 31-49 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - While the University had effective controls that were successful in achieving the 30-calendar-day requirement for 52 samples, the University failed to provide supplemental support and preventive controls during a period when it was addressing an issue that prevented timely payment for certain subrecipients. Recommendation - The University should ensure appropriate training of employees is taking place and a preventive control is implemented to ensure that payments are made within the required timeline. Views of Responsible Officials and Corrective Action Plan - Purdue University will address the recommendations and implement the following preventive controls to ensure that payments are made within the required timeline. 1. The Office of Research will increase the priority around the 30-day processing deadline mandated by the Uniform Guidance 2 FR 200.305 (b)(3). This will be accomplished through communications, training, and expectation setting with the following audiences: a. Principal investigators of active grants with sub-awards i. Blanket communication ii. Add the expected turnaround time on each subrecipient communication when seeking principal investigator review and approval b. Sub-award team in sponsored program i. Blanket communication ii. Add the expected turnaround time to the expectations document for each sub-award team member iii. Add sub-recipient payment deadlines to the mandatory training for the sub-award team iv. Update payment terms to “Payable immediately Due net; Based on Doc Date” for all subrecipient invoices 2. We will begin using the date the invoice is received at Purdue University in our financial system instead of the date on the invoice for tracking purposes. 3. Create a report for internal reporting and tracking of pending subinvoices to improve awareness of payments approaching the 30-day deadline.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 47.041, National Science Foundation, Engineering Grants - 93.855, U.S. Department of Health and Human Services, Allergy, Immunology and Transplantation Research - 12.910, U.S. Department of Interior, Research and Technology Development (R & D) - 12.431, U.S. Department of Defense, Basic Scientific Research Federal Award Identification Number and Year - 47.041 - 1855937-CBET - 93.855 - 5R01AI158220-02 - 12.910 - D18AC00024 - 12.431 - W52P1J-22-9-3009; W52P1J-20-9-3009-10 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a 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. Condition - The University did not have adequate controls in place to ensure invoices to subrecipients were paid timely within the 30-calendar-day requirement. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - There were no questioned costs identified. Context - Out of 60 payments to subrecipients that were tested related to the R&D Cluster, 8 were made after the 30-calendar-day requirement. In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 31-49 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - While the University had effective controls that were successful in achieving the 30-calendar-day requirement for 52 samples, the University failed to provide supplemental support and preventive controls during a period when it was addressing an issue that prevented timely payment for certain subrecipients. Recommendation - The University should ensure appropriate training of employees is taking place and a preventive control is implemented to ensure that payments are made within the required timeline. Views of Responsible Officials and Corrective Action Plan - Purdue University will address the recommendations and implement the following preventive controls to ensure that payments are made within the required timeline. 1. The Office of Research will increase the priority around the 30-day processing deadline mandated by the Uniform Guidance 2 FR 200.305 (b)(3). This will be accomplished through communications, training, and expectation setting with the following audiences: a. Principal investigators of active grants with sub-awards i. Blanket communication ii. Add the expected turnaround time on each subrecipient communication when seeking principal investigator review and approval b. Sub-award team in sponsored program i. Blanket communication ii. Add the expected turnaround time to the expectations document for each sub-award team member iii. Add sub-recipient payment deadlines to the mandatory training for the sub-award team iv. Update payment terms to “Payable immediately Due net; Based on Doc Date” for all subrecipient invoices 2. We will begin using the date the invoice is received at Purdue University in our financial system instead of the date on the invoice for tracking purposes. 3. Create a report for internal reporting and tracking of pending subinvoices to improve awareness of payments approaching the 30-day deadline.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 47.041, National Science Foundation, Engineering Grants - 93.855, U.S. Department of Health and Human Services, Allergy, Immunology and Transplantation Research - 12.910, U.S. Department of Interior, Research and Technology Development (R & D) - 12.431, U.S. Department of Defense, Basic Scientific Research Federal Award Identification Number and Year - 47.041 - 1855937-CBET - 93.855 - 5R01AI158220-02 - 12.910 - D18AC00024 - 12.431 - W52P1J-22-9-3009; W52P1J-20-9-3009-10 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a 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. Condition - The University did not have adequate controls in place to ensure invoices to subrecipients were paid timely within the 30-calendar-day requirement. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - There were no questioned costs identified. Context - Out of 60 payments to subrecipients that were tested related to the R&D Cluster, 8 were made after the 30-calendar-day requirement. In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 31-49 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - While the University had effective controls that were successful in achieving the 30-calendar-day requirement for 52 samples, the University failed to provide supplemental support and preventive controls during a period when it was addressing an issue that prevented timely payment for certain subrecipients. Recommendation - The University should ensure appropriate training of employees is taking place and a preventive control is implemented to ensure that payments are made within the required timeline. Views of Responsible Officials and Corrective Action Plan - Purdue University will address the recommendations and implement the following preventive controls to ensure that payments are made within the required timeline. 1. The Office of Research will increase the priority around the 30-day processing deadline mandated by the Uniform Guidance 2 FR 200.305 (b)(3). This will be accomplished through communications, training, and expectation setting with the following audiences: a. Principal investigators of active grants with sub-awards i. Blanket communication ii. Add the expected turnaround time on each subrecipient communication when seeking principal investigator review and approval b. Sub-award team in sponsored program i. Blanket communication ii. Add the expected turnaround time to the expectations document for each sub-award team member iii. Add sub-recipient payment deadlines to the mandatory training for the sub-award team iv. Update payment terms to “Payable immediately Due net; Based on Doc Date” for all subrecipient invoices 2. We will begin using the date the invoice is received at Purdue University in our financial system instead of the date on the invoice for tracking purposes. 3. Create a report for internal reporting and tracking of pending subinvoices to improve awareness of payments approaching the 30-day deadline.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 47.041, National Science Foundation, Engineering Grants - 93.855, U.S. Department of Health and Human Services, Allergy, Immunology and Transplantation Research - 12.910, U.S. Department of Interior, Research and Technology Development (R & D) - 12.431, U.S. Department of Defense, Basic Scientific Research Federal Award Identification Number and Year - 47.041 - 1855937-CBET - 93.855 - 5R01AI158220-02 - 12.910 - D18AC00024 - 12.431 - W52P1J-22-9-3009; W52P1J-20-9-3009-10 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a 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. Condition - The University did not have adequate controls in place to ensure invoices to subrecipients were paid timely within the 30-calendar-day requirement. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - There were no questioned costs identified. Context - Out of 60 payments to subrecipients that were tested related to the R&D Cluster, 8 were made after the 30-calendar-day requirement. In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 31-49 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - While the University had effective controls that were successful in achieving the 30-calendar-day requirement for 52 samples, the University failed to provide supplemental support and preventive controls during a period when it was addressing an issue that prevented timely payment for certain subrecipients. Recommendation - The University should ensure appropriate training of employees is taking place and a preventive control is implemented to ensure that payments are made within the required timeline. Views of Responsible Officials and Corrective Action Plan - Purdue University will address the recommendations and implement the following preventive controls to ensure that payments are made within the required timeline. 1. The Office of Research will increase the priority around the 30-day processing deadline mandated by the Uniform Guidance 2 FR 200.305 (b)(3). This will be accomplished through communications, training, and expectation setting with the following audiences: a. Principal investigators of active grants with sub-awards i. Blanket communication ii. Add the expected turnaround time on each subrecipient communication when seeking principal investigator review and approval b. Sub-award team in sponsored program i. Blanket communication ii. Add the expected turnaround time to the expectations document for each sub-award team member iii. Add sub-recipient payment deadlines to the mandatory training for the sub-award team iv. Update payment terms to “Payable immediately Due net; Based on Doc Date” for all subrecipient invoices 2. We will begin using the date the invoice is received at Purdue University in our financial system instead of the date on the invoice for tracking purposes. 3. Create a report for internal reporting and tracking of pending subinvoices to improve awareness of payments approaching the 30-day deadline.
HEERF INSTITUTIONAL AID SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUE) YEAR ENDED JUNE 30, 2023 CASH MANAGEMENT FINDING NO. 2023-002 – TIME ELAPSING BETWEEN THE TRANSFER OF FUNDS CRITERIA Schools must minimize the time elapsing between the transfer of funds from ED and disbursement by the school 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)). What constitutes minimized elapsed time for funds transfer will depend on what payment system/method a school uses. Under the advance payment method, payment is made to the school before the school disburses the funds for program purposes (2 CFR section 200.3). Some schools’ grants may have been placed on Route Pay or Stop Pay Status, as indicated by a notification the grantee would have received from ED. This requires ED approval of a spending plan prior to the grantee drawing down funds or the submission of single requests with documentation. For CRRSAA HEERF II and ARP HEERF III, the Certification and Agreement and/or Supplemental Agreement indicate that Student Aid (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from ED’s grant management system (G5), while Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the drawdown from G5. CONDITION During our field work in the cash management area, we noted funds that were requested to G-5 but not disbursed by UPM to minimize the time elapsing between the transfer of funds and disbursement as follows: Description Dates Amount Funds receceived from G-5 on June 8, 2022 6/8/2022 $610,710.35 Funds disbursed during 2022-2023 Fiscal year 2022-23 (525,362.27) Available balance from funds received in 6/8/2022 6/30/2023 $ 75,348.08 Funds receceived from G-5 on June 22, 2023 6/22/2023 $319,251.71 Funds disbursed at the end of fiscal year 2022-2023 6/30/2023 ( 45,000) Available balance from funds received in 6/22/2023 6/30/2023 $274,251.71 HEERF INSTITUTIONAL AID SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUE) YEAR ENDED JUNE 30, 2023 CASH MANAGEMENT (CONTINUE) FINDING NO. 2023-002 – TRANSFER OF FUNDS BEYOND THE REQUIRED TIME LIMITS EFFECT The drawdowns of Federal funds made by UPM not minimized the time elapsing between transfer of funds and the disbursement by the university according to regulations. QUESTIONED COSTS $0.00 CAUSE This situation occurred due to UPM did not make adequate follow up to the cash advances received from G-5 RECOMMENDATION The University should reinforce the procedures the drawdown of funds to comply with the regulation applicable for the transfer of funds through the G-5 system. VIEWS OF RESPONSIBLE OFFICIALS See the Corrective Action Plan for details of action required.
Program: AL 12.401 – National Guard Military Operations and Maintenance (O&M) Projects – Cash Management & Reporting Grant Number & Year: Appendices – W91243-21-2-1001, FFY 2021; W91243-22-2-1001, FFY 2022; W91243-22-2-1002, FFY 2022; W91243-22-2-1005, FFY 2022; W91243-22-2-1007, FFY 2022; W91243-22-2-1021, FFY 2022; W91243-22-2-1023, FFY 2022; W91243-22-2-1031, FFY 2022; W91243-23-2-1001, FFY 2023; W91243-23-2-1003, FFY 2023; W91243-23-2-1005, FFY 2023; W91243-23-2-1010, FFY 2023; W91243-23-2-1021, FFY 2023; W91243-23-2-1023, FFY 2023; W91243-23-2-1024, FFY 2023; W91243-23-2-1031, FFY 2023. Federal Grantor Agency: U.S. Department of Defense Criteria: Per 2 CFR § 1128.100 and 2 CFR § 1128.200 (January 1, 2023), the Department of Defense adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements set forth at 2 CFR parts 200.302, 200.303, and 200.305. Per 2 CFR § 200.303 (January 1, 2023): 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. Title 2 CFR § 200.302 (January 1, 2023) requires financial management systems of the State be sufficient to permit both the preparation of required reports and tracing of funds to expenditures adequate to establish that the use of these funds was in accordance with applicable regulations. EnterpriseOne is the official accounting system for the State of Nebraska, and all expenditures are generated from it. Title 2 CFR § 200.305(a) (January 1, 2023) states, in part, “For states, payments are governed by Treasury-State Cash Management Improvement Act (CMIA) agreements and default procedures codified at 31 CFR part 205 . . . .” Title 31 CFR Part 205 (July 1, 2022) implements the CMIA and requires State recipients to enter into agreements that document accepted funding techniques for Federal assistance programs. The CMIA Agreement between the State of Nebraska, Secretary of the Treasury, and U.S. Department of the Treasury, for the period July 1, 2022, through June 30, 2023, allows the program to request Federal funds in accordance with the monthly draw funding technique, which bases the amount requested on costs estimated to be incurred in the next month. Master Cooperative Agreement (October 2022), Article V – Payment, Section 503, Payment by Advance Method, states, “The advance payment method shall be according to procedures established in current NGB-AQ policy, NGR 5-1 Chapter 11 or successor CNGB I & M, and 2 CFR §200.305.” National Guard Policy (NG Policy) 5-1, National Guard Grants and Cooperative Agreements, Section 11-5, Advance Payment Method, Section (5), states, in part, “[T]he grantee agrees to minimize the time elapsing between the transfer of funds from the U.S. Treasury and their disbursement by the State. (no more than 45 days).” GCAPL 20-02 AQ-A Policy (February 4, 2020) turned NGR 5-1 into NG Policy 5-1. It generally maintained the principles and operational aspects of NGR 5-1, except as provisions of the document were adjusted in the AQ-A Policy. The AQ-A Policy did not make any changes to the 45-day requirement found in NGR 5-1. Instructions for OMB Standard Form 270 (REV. 1/2016) include the following for line 11a, “Enter program outlays to date (net of refunds, rebates, and discounts), in the appropriate columns. For requests prepared on a cash basis, outlays are the sum of actual cash disbursements for goods and services, the amount of indirect expenses charged, the value of in- kind contributions applied, and the amount of cash advances and payments made to subcontractors and subrecipients.” Title 2 CFR § 200.511(b) (January 1, 2023) states in relevant part, the following: The summary schedule of prior audit findings must report the status of all audit findings included in the prior audit’s schedule of findings and questioned costs. . . . * * * * (2) When audit findings were not corrected or were only partially corrected, the summary schedule must describe the reasons for the finding's recurrence and planned corrective action, and any partial corrective action taken. When corrective action taken is significantly different from corrective action previously reported in a corrective action plan or in the Federal agency's or pass-through entity's management decision, the summary schedule must provide an explanation. A good internal control plan would include procedures to ensure that the times between the drawdown of Federal funds and the disbursements thereof are minimized and in compliance with State of Nebraska CMIA Agreement and National Guard Regulations. Condition: The Agency was not in compliance with the Federal cash management requirements during the fiscal year and did not properly report program outlays on the OMB Standard Form (SF) 270. A similar finding was noted in the prior audit. Repeat Finding: 2022-050 Questioned Costs: None Statistical Sample: No Context: We tested 25 drawdowns of Federal funds to support the Agency’s operations and noted the following: • Eleven drawdowns were not in compliance with NG Policy 5-1. The draws were expended from 48 to 166 days after the drawdown of Federal funds. The table below provides a summary of the 11 draws: See Schedule of Findings and Questioned Costs for chart/table. • In addition, five draws were not in compliance with CMIA Agreement requirements. Advance amounts were requested based on estimated costs to be incurred during the month covered by the requests. To determine the reasonableness of the estimates, the APA determined the time it took the Agency to expend amounts advanced (without consideration of any cash on hand). Five draws were expended between 48 and 111 days after the drawdown of Federal funds. • For 23 of 25 SF-270’s tested, the Agency did not properly report total program outlays on the OMB SF-270 report. The Agency reported the total drawdowns for the program to date, rather than actual cash disbursements, as total program outlays. The variance between what was reported and what should have been reported ranged from an underreporting of $45,247 to an overreporting of $1,143,496, with a net total overreporting of expenditures by $5,104,828 for the 25 reports tested. A similar finding was noted during the previous audit. In the Summary Schedule of Prior Audit Findings, the Agency stated the following as a reason for the recurrence: The requirement per the CMIA Agreement which requires the program to request Federal funds in accordance with the pre-issuance funding technique and that such funds are to be requested and deposited in a state account not more than three business days prior to disbursement of funds is not a reasonable standard for the National Guard Military Operations and Maintenance Program. The Agency stated further that it will seek a modification to the CMIA Agreement. However, under the State’s fiscal year 2022 and 2023 CMIA Agreements, the program is no longer required to follow the pre-issuance funding technique and instead follows the monthly draw funding technique. Thus, the Summary Schedule of Prior Audit Findings is not accurate. Cause: Inadequate procedures for estimating cash needs for the upcoming month. Regarding SF-270 reporting, the Agency stated that it did not plan to implement corrective action until State fiscal year 2024. Effect: The Agency is not in compliance with Federal cash management and reporting requirements, which could result in sanctions. Additionally, there is an increased risk for the loss of Federal funding. Recommendation: We recommend the Agency ensure the amount of time between the Federal draw and the disbursement of funds by the State is minimized and in compliance with the State of Nebraska CMIA Agreement and National Guard requirements. We also recommend the Agency report total program outlays in compliance with Federal requirements. Management Response: The Agency agrees with the finding. The drawdown timeline is a partial result of the variances in federal reimbursement functionalities and advance state requirement functionalities. The State Services Support Division has simultaneously been prioritizing workloads due to staffing shortages persistent through the first quarter end of fiscal year 2023-2024.
Department of Environmental Protection Finding 2023 –¬ 011: ALN 15.252 – Abandoned Mine Land Reclamation A Material Weakness and Material Noncompliance Exist at the Department of Environmental Protection Related to Cash Management of Federal Funds Federal Grant Number(s) and Year(s): S21AF10050 (6/01/2021 – 5/31/2024) Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Compliance Requirement: Cash Management Condition: The Department of Environmental Protection (DEP) administers the Abandoned Mine Land Reclamation (AMLR) program funded by the United States Department of the Interior (DOI). During the fiscal year ended June 30, 2023, DEP expended $60,055,889 within the AMLR program, $8,900,470 or 14.8% of which was transferred to the Commonwealth Department of General Services (DGS) on July 6, 2022. DEP signed a Letter of Commitment (LOC) with DGS agreeing to transfer the funds as partial funding of a Capital Budget project for a third-party contractor to construct a new Acid Mine Drainage treatment facility estimated to cost approximately $26 million. Once transferred to DGS, these federal funds were combined with state Capital Budget funds and encumbered until project contractor payments began later in the fiscal year. Our review of transaction dates disclosed that DEP drew down $8,900,470 of AMLR federal funds on July 8, 2022; however, contractor payments did not begin until November 2022. A total of $9.1 million in contract payments were expended by the Commonwealth between November 2022 and June 30, 2023 fiscal year end. Therefore, DEP did not adequately limit the time between the drawdown of federal funds and the Commonwealth’s need for those funds, resulting in noncompliance with federal cash management regulations. Criteria: As part of administering the AMLR program, DEP must have policies, procedures, and controls in place to ensure compliance with federal cash management requirements and regulations. 2 CFR Section 200.305 (a), Federal Payment for pass through entities, states in part: a) For states, payments are governed by Treasury-State Cash Management Improvement Act (CMIA) agreements and default procedures codified at 31 CFR part 205. 31 CFR Section 205.33 (a) states in part: (a) A State must minimize the time between the drawdown of Federal funds from the Federal government and their disbursement for Federal program purposes. A Federal Program Agency must limit a funds transfer to a State to the minimum amounts needed by the State and must time the disbursement to be in accord with the actual, immediate cash requirements of the State in carrying out a Federal assistance program or project. The timing and amount of funds transfers must be as close as is administratively feasible to a State's actual cash outlay for direct program costs and the proportionate share of any allowable indirect costs. States should exercise sound cash management in funds transfers to subgrantees… Commonwealth Management Directive 325.12 Amended – Standards for Enterprise Risk Management in Commonwealth Agencies, adopted the internal control framework outlined in the United States Government Accountability Office’s Standards for Internal Control in the Federal Government (Green Book). The Green Book states in part: Finding 2023 –¬ 011: (continued) Management should design control activities to achieve objectives and respond to risk. Management should implement control activities through policies. Cause: DGS has sole oversight of Capital Budget projects, one of which was partially funded by AMLR funds under the LOC between DEP and DGS. To have funds available for timely contract award, it is DGS practice to bill the agency for the entirety of the funds committed, including federal funds in this case, when a LOC is executed. Once transferred from the agency, funds are encumbered and held until project contractor payments are made. DEP did not have procedures in place to minimize the time between the drawdown of federal funds and their disbursement by DGS for project purposes. Effect: DEP did not minimize the time elapsing between the drawdown of $8,900,470 in AMLR funds and the actual need for the funds, resulting in noncompliance with federal cash management regulations. Recommendation: We recommend DEP implement policies and procedures when a LOC is executed for any future Capital Budget projects to minimize the time federal funds are held by the Commonwealth. Agency Response: DEP agrees with the facts presented in this finding. Questioned Costs: None
Section IV - Federal Award and State Projects Findings and Questioned Costs Findings and Questioned Costs – Major Federal Programs Finding 2023-001: Internal Control over Compliance and Compliance with Cash Management Federal Programs: ALN 93.575/93.596, and 93.558 Criteria: In accordance with the grant agreement and 2 CFR 200.305(8) and (9), the non-Federal entity must maintain advance payments of Federal awards in interest-bearing accounts. Interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services. Condition: The Coalition has a cash management policy in accordance with federal regulations, however, the policy was not followed. Federal funds were deposited into non-interest-bearing accounts. Cause: Lack of effective controls surrounding cash management and review of controls to ensure compliance with federal regulations. Effect: The Coalition has not accrued interest on DEL grant funds in accordance with federal regulations. Recommendation: We recommend the Coalition transfer all DEL grant funds to its interest-bearing account and return accrued interest to DEL. Management’s Response: See Management’s Corrective Action Plan beginning on page 25.
Section IV - Federal Award and State Projects Findings and Questioned Costs Findings and Questioned Costs – Major Federal Programs Finding 2023-001: Internal Control over Compliance and Compliance with Cash Management Federal Programs: ALN 93.575/93.596, and 93.558 Criteria: In accordance with the grant agreement and 2 CFR 200.305(8) and (9), the non-Federal entity must maintain advance payments of Federal awards in interest-bearing accounts. Interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services. Condition: The Coalition has a cash management policy in accordance with federal regulations, however, the policy was not followed. Federal funds were deposited into non-interest-bearing accounts. Cause: Lack of effective controls surrounding cash management and review of controls to ensure compliance with federal regulations. Effect: The Coalition has not accrued interest on DEL grant funds in accordance with federal regulations. Recommendation: We recommend the Coalition transfer all DEL grant funds to its interest-bearing account and return accrued interest to DEL. Management’s Response: See Management’s Corrective Action Plan beginning on page 25.
Section IV - Federal Award and State Projects Findings and Questioned Costs Findings and Questioned Costs – Major Federal Programs Finding 2023-001: Internal Control over Compliance and Compliance with Cash Management Federal Programs: ALN 93.575/93.596, and 93.558 Criteria: In accordance with the grant agreement and 2 CFR 200.305(8) and (9), the non-Federal entity must maintain advance payments of Federal awards in interest-bearing accounts. Interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services. Condition: The Coalition has a cash management policy in accordance with federal regulations, however, the policy was not followed. Federal funds were deposited into non-interest-bearing accounts. Cause: Lack of effective controls surrounding cash management and review of controls to ensure compliance with federal regulations. Effect: The Coalition has not accrued interest on DEL grant funds in accordance with federal regulations. Recommendation: We recommend the Coalition transfer all DEL grant funds to its interest-bearing account and return accrued interest to DEL. Management’s Response: See Management’s Corrective Action Plan beginning on page 25.
Section IV - Federal Award and State Projects Findings and Questioned Costs Findings and Questioned Costs – Major Federal Programs Finding 2023-001: Internal Control over Compliance and Compliance with Cash Management Federal Programs: ALN 93.575/93.596, and 93.558 Criteria: In accordance with the grant agreement and 2 CFR 200.305(8) and (9), the non-Federal entity must maintain advance payments of Federal awards in interest-bearing accounts. Interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services. Condition: The Coalition has a cash management policy in accordance with federal regulations, however, the policy was not followed. Federal funds were deposited into non-interest-bearing accounts. Cause: Lack of effective controls surrounding cash management and review of controls to ensure compliance with federal regulations. Effect: The Coalition has not accrued interest on DEL grant funds in accordance with federal regulations. Recommendation: We recommend the Coalition transfer all DEL grant funds to its interest-bearing account and return accrued interest to DEL. Management’s Response: See Management’s Corrective Action Plan beginning on page 25.
Section IV - Federal Award and State Projects Findings and Questioned Costs Findings and Questioned Costs – Major Federal Programs Finding 2023-001: Internal Control over Compliance and Compliance with Cash Management Federal Programs: ALN 93.575/93.596, and 93.558 Criteria: In accordance with the grant agreement and 2 CFR 200.305(8) and (9), the non-Federal entity must maintain advance payments of Federal awards in interest-bearing accounts. Interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services. Condition: The Coalition has a cash management policy in accordance with federal regulations, however, the policy was not followed. Federal funds were deposited into non-interest-bearing accounts. Cause: Lack of effective controls surrounding cash management and review of controls to ensure compliance with federal regulations. Effect: The Coalition has not accrued interest on DEL grant funds in accordance with federal regulations. Recommendation: We recommend the Coalition transfer all DEL grant funds to its interest-bearing account and return accrued interest to DEL. Management’s Response: See Management’s Corrective Action Plan beginning on page 25.
Section IV - Federal Award and State Projects Findings and Questioned Costs Findings and Questioned Costs – Major Federal Programs Finding 2023-001: Internal Control over Compliance and Compliance with Cash Management Federal Programs: ALN 93.575/93.596, and 93.558 Criteria: In accordance with the grant agreement and 2 CFR 200.305(8) and (9), the non-Federal entity must maintain advance payments of Federal awards in interest-bearing accounts. Interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services. Condition: The Coalition has a cash management policy in accordance with federal regulations, however, the policy was not followed. Federal funds were deposited into non-interest-bearing accounts. Cause: Lack of effective controls surrounding cash management and review of controls to ensure compliance with federal regulations. Effect: The Coalition has not accrued interest on DEL grant funds in accordance with federal regulations. Recommendation: We recommend the Coalition transfer all DEL grant funds to its interest-bearing account and return accrued interest to DEL. Management’s Response: See Management’s Corrective Action Plan beginning on page 25.
Section IV - Federal Award and State Projects Findings and Questioned Costs Findings and Questioned Costs – Major Federal Programs Finding 2023-001: Internal Control over Compliance and Compliance with Cash Management Federal Programs: ALN 93.575/93.596, and 93.558 Criteria: In accordance with the grant agreement and 2 CFR 200.305(8) and (9), the non-Federal entity must maintain advance payments of Federal awards in interest-bearing accounts. Interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services. Condition: The Coalition has a cash management policy in accordance with federal regulations, however, the policy was not followed. Federal funds were deposited into non-interest-bearing accounts. Cause: Lack of effective controls surrounding cash management and review of controls to ensure compliance with federal regulations. Effect: The Coalition has not accrued interest on DEL grant funds in accordance with federal regulations. Recommendation: We recommend the Coalition transfer all DEL grant funds to its interest-bearing account and return accrued interest to DEL. Management’s Response: See Management’s Corrective Action Plan beginning on page 25.
Section IV - Federal Award and State Projects Findings and Questioned Costs Findings and Questioned Costs – Major Federal Programs Finding 2023-001: Internal Control over Compliance and Compliance with Cash Management Federal Programs: ALN 93.575/93.596, and 93.558 Criteria: In accordance with the grant agreement and 2 CFR 200.305(8) and (9), the non-Federal entity must maintain advance payments of Federal awards in interest-bearing accounts. Interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services. Condition: The Coalition has a cash management policy in accordance with federal regulations, however, the policy was not followed. Federal funds were deposited into non-interest-bearing accounts. Cause: Lack of effective controls surrounding cash management and review of controls to ensure compliance with federal regulations. Effect: The Coalition has not accrued interest on DEL grant funds in accordance with federal regulations. Recommendation: We recommend the Coalition transfer all DEL grant funds to its interest-bearing account and return accrued interest to DEL. Management’s Response: See Management’s Corrective Action Plan beginning on page 25.
FINDING 2023-003 Information on the federal program: Subject: Education Stabilization Fund – Advance Draws Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs- Cost Principles Audit Finding: Material Weakness, Other Matters Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR section 200.305 states in part: (b) 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. FINDING 2023-003 (Continued) The non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. 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. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions. Condition: The School Corporation requested reimbursement prior to incurring expenditures under federal grant awards. An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, Allowable Costs- Cost Principles compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Requesting advance payments prior to incurring allowable costs could result in disallowed costs or an interest obligation owed to the federal government. Questioned Costs: $38,379 of known questioned costs has been identified. This represents the amount of advance payment received and not yet spent at June 30, 2023. Context: During testing disbursements charged to ESF grants, we noted the ESSER I grant award, tracked in Fund 7940, and the ESSER III grant award, tracked in Fund 7932, had a positive cash balance of $2,718 and $35,661, respectively, at June 30, 2023 as a result of advance payments received during fiscal year 2023. The School Corporation submitted a request for reimbursement on November 15, 2022 for $21,745 from the ESSER I grant award and $565,876 from the ESSER III grant award, respectively. These requests for reimbursements were partially supported by disbursements incurred as of the date of the request, however, partially include requests for advance payments that were still not fully expended as of June 30, 2023. Identification as a repeat finding, if applicable: No. Recommendation: We recommended the School Corporation review the internal controls surrounding the reimbursement request process and ensure claims for reimbursements are supported by costs incurred prior to the submission of the request for reimbursement. For any requests for advance payments, the School Corporation should seek pre-approval from the Indiana Department of Education prior to making any requests for advance payments and implement controls to minimize the time between drawing and disbursing federal funds. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2023-003 Information on the federal program: Subject: Education Stabilization Fund – Advance Draws Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs- Cost Principles Audit Finding: Material Weakness, Other Matters Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR section 200.305 states in part: (b) 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. FINDING 2023-003 (Continued) The non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. 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. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions. Condition: The School Corporation requested reimbursement prior to incurring expenditures under federal grant awards. An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, Allowable Costs- Cost Principles compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Requesting advance payments prior to incurring allowable costs could result in disallowed costs or an interest obligation owed to the federal government. Questioned Costs: $38,379 of known questioned costs has been identified. This represents the amount of advance payment received and not yet spent at June 30, 2023. Context: During testing disbursements charged to ESF grants, we noted the ESSER I grant award, tracked in Fund 7940, and the ESSER III grant award, tracked in Fund 7932, had a positive cash balance of $2,718 and $35,661, respectively, at June 30, 2023 as a result of advance payments received during fiscal year 2023. The School Corporation submitted a request for reimbursement on November 15, 2022 for $21,745 from the ESSER I grant award and $565,876 from the ESSER III grant award, respectively. These requests for reimbursements were partially supported by disbursements incurred as of the date of the request, however, partially include requests for advance payments that were still not fully expended as of June 30, 2023. Identification as a repeat finding, if applicable: No. Recommendation: We recommended the School Corporation review the internal controls surrounding the reimbursement request process and ensure claims for reimbursements are supported by costs incurred prior to the submission of the request for reimbursement. For any requests for advance payments, the School Corporation should seek pre-approval from the Indiana Department of Education prior to making any requests for advance payments and implement controls to minimize the time between drawing and disbursing federal funds. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2023-003 Information on the federal program: Subject: Education Stabilization Fund – Advance Draws Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers: S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs- Cost Principles Audit Finding: Material Weakness, Qualified Opinion Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR section 200.305 states in part: (b) 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. (1) The non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. 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. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions. Condition: The School Corporation requested reimbursement prior to incurring expenditures under federal grant awards. An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, Allowable Costs- Cost Principles compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. FINDING 2023-003 (Continued) Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Requesting advance payments prior to incurring allowable costs could result in disallowed costs or an interest obligation owed to the federal government. Questioned Costs: $37,987 of known questioned costs has been identified. This represents the amount of advance payment received and not yet spent at June 30, 2023. Context: During testing disbursements charged to ESF grants, we noted advance payments were received during the audit period prior to allowable costs being incurred by the School Corporation impacting the following Education Stabilization Fund grant awards: The School Corporation submitted a claim for reimbursement for $43,864 from the ESSER I grant award (84.425D) which was receipted on August 24, 2021. As of August 24, 2021, the School Corporation had incurred $41,674 of grant expenditures. The remaining $2,190 was disbursed on April 12, 2022. The School Corporation submitted a claim for reimbursement for $148,822 from the ESSER II grant award (84.425D) which was receipted on July 28, 2021. There were no expenditures incurred as of the date of the reimbursement request. The School Corporation began incurring expenditures after the advance payment, however, as of June 30, 2022, the School Corporation had an unspent cash balance of $24,613 in the ESSER II fund because of the advance payment. The School Corporation did not request any reimbursements for the period of July 1, 2022 through June 30, 2023 and continued to incur expenditures. As of June 30, 2023, the School Corporation had an u nspent cash balance of $16,145. The School Corporation submitted two claims for reimbursements from the ESSER III grant award (84.425U) during fiscal year 2022. The first claim reimbursement was receipted on November 24, 2021, in the amount of $52,210. The second claim reimbursement request was receipted on June 22, 2022, in the amount of $144,649. The School Corporation had incurred expenditures as of the date of each claim reimbursement requests, however, the amount claimed for reimbursement exceeded expenditures incurred resulting in advance payments being received. As of June 30, 2022, the School Corporation had an unspent cash balance of $88,348 in the ESSER III fund as a result of the advance payment. The School Corporation did not request any claims for reimbursements for the period of July 1, 2022 through June 30, 2023 and continued to incur expenditures. As of June 30, 2023, the School Corporation had an unspent cash balance of $21,842 in the ESSER III fund because of the advance payments. Identification as a repeat finding, if applicable: No. Recommendation: We recommended the School Corporation review the internal controls surrounding the reimbursement request process and ensure claims for reimbursements are supported by costs incurred prior to the submission of the request for reimbursement. For any requests for advance payments, the School Corporation should seek pre-approval from the the Indiana Department of Education prior to making any requests for advance payments and implement controls to minimize the time between drawing and disbursing federal funds. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2023-003 Information on the federal program: Subject: Education Stabilization Fund – Advance Draws Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers: S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs- Cost Principles Audit Finding: Material Weakness, Qualified Opinion Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR section 200.305 states in part: (b) 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. (1) The non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. 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. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions. Condition: The School Corporation requested reimbursement prior to incurring expenditures under federal grant awards. An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, Allowable Costs- Cost Principles compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. FINDING 2023-003 (Continued) Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Requesting advance payments prior to incurring allowable costs could result in disallowed costs or an interest obligation owed to the federal government. Questioned Costs: $37,987 of known questioned costs has been identified. This represents the amount of advance payment received and not yet spent at June 30, 2023. Context: During testing disbursements charged to ESF grants, we noted advance payments were received during the audit period prior to allowable costs being incurred by the School Corporation impacting the following Education Stabilization Fund grant awards: The School Corporation submitted a claim for reimbursement for $43,864 from the ESSER I grant award (84.425D) which was receipted on August 24, 2021. As of August 24, 2021, the School Corporation had incurred $41,674 of grant expenditures. The remaining $2,190 was disbursed on April 12, 2022. The School Corporation submitted a claim for reimbursement for $148,822 from the ESSER II grant award (84.425D) which was receipted on July 28, 2021. There were no expenditures incurred as of the date of the reimbursement request. The School Corporation began incurring expenditures after the advance payment, however, as of June 30, 2022, the School Corporation had an unspent cash balance of $24,613 in the ESSER II fund because of the advance payment. The School Corporation did not request any reimbursements for the period of July 1, 2022 through June 30, 2023 and continued to incur expenditures. As of June 30, 2023, the School Corporation had an u nspent cash balance of $16,145. The School Corporation submitted two claims for reimbursements from the ESSER III grant award (84.425U) during fiscal year 2022. The first claim reimbursement was receipted on November 24, 2021, in the amount of $52,210. The second claim reimbursement request was receipted on June 22, 2022, in the amount of $144,649. The School Corporation had incurred expenditures as of the date of each claim reimbursement requests, however, the amount claimed for reimbursement exceeded expenditures incurred resulting in advance payments being received. As of June 30, 2022, the School Corporation had an unspent cash balance of $88,348 in the ESSER III fund as a result of the advance payment. The School Corporation did not request any claims for reimbursements for the period of July 1, 2022 through June 30, 2023 and continued to incur expenditures. As of June 30, 2023, the School Corporation had an unspent cash balance of $21,842 in the ESSER III fund because of the advance payments. Identification as a repeat finding, if applicable: No. Recommendation: We recommended the School Corporation review the internal controls surrounding the reimbursement request process and ensure claims for reimbursements are supported by costs incurred prior to the submission of the request for reimbursement. For any requests for advance payments, the School Corporation should seek pre-approval from the the Indiana Department of Education prior to making any requests for advance payments and implement controls to minimize the time between drawing and disbursing federal funds. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2023-003 Information on the federal program: Subject: Education Stabilization Fund – Advance Draws Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers: S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs- Cost Principles Audit Finding: Material Weakness, Qualified Opinion Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR section 200.305 states in part: (b) 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. (1) The non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. 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. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions. Condition: The School Corporation requested reimbursement prior to incurring expenditures under federal grant awards. An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, Allowable Costs- Cost Principles compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. FINDING 2023-003 (Continued) Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Requesting advance payments prior to incurring allowable costs could result in disallowed costs or an interest obligation owed to the federal government. Questioned Costs: $37,987 of known questioned costs has been identified. This represents the amount of advance payment received and not yet spent at June 30, 2023. Context: During testing disbursements charged to ESF grants, we noted advance payments were received during the audit period prior to allowable costs being incurred by the School Corporation impacting the following Education Stabilization Fund grant awards: The School Corporation submitted a claim for reimbursement for $43,864 from the ESSER I grant award (84.425D) which was receipted on August 24, 2021. As of August 24, 2021, the School Corporation had incurred $41,674 of grant expenditures. The remaining $2,190 was disbursed on April 12, 2022. The School Corporation submitted a claim for reimbursement for $148,822 from the ESSER II grant award (84.425D) which was receipted on July 28, 2021. There were no expenditures incurred as of the date of the reimbursement request. The School Corporation began incurring expenditures after the advance payment, however, as of June 30, 2022, the School Corporation had an unspent cash balance of $24,613 in the ESSER II fund because of the advance payment. The School Corporation did not request any reimbursements for the period of July 1, 2022 through June 30, 2023 and continued to incur expenditures. As of June 30, 2023, the School Corporation had an u nspent cash balance of $16,145. The School Corporation submitted two claims for reimbursements from the ESSER III grant award (84.425U) during fiscal year 2022. The first claim reimbursement was receipted on November 24, 2021, in the amount of $52,210. The second claim reimbursement request was receipted on June 22, 2022, in the amount of $144,649. The School Corporation had incurred expenditures as of the date of each claim reimbursement requests, however, the amount claimed for reimbursement exceeded expenditures incurred resulting in advance payments being received. As of June 30, 2022, the School Corporation had an unspent cash balance of $88,348 in the ESSER III fund as a result of the advance payment. The School Corporation did not request any claims for reimbursements for the period of July 1, 2022 through June 30, 2023 and continued to incur expenditures. As of June 30, 2023, the School Corporation had an unspent cash balance of $21,842 in the ESSER III fund because of the advance payments. Identification as a repeat finding, if applicable: No. Recommendation: We recommended the School Corporation review the internal controls surrounding the reimbursement request process and ensure claims for reimbursements are supported by costs incurred prior to the submission of the request for reimbursement. For any requests for advance payments, the School Corporation should seek pre-approval from the the Indiana Department of Education prior to making any requests for advance payments and implement controls to minimize the time between drawing and disbursing federal funds. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Assistance Listing Number(s), Federal Agency and Program Name: 84.031F and 84.031C; United States Department of Education (ED) , and 47.076; National Science Foundation (NSF), Research and Development Cluster. Finding Type: Noncompliance and significant deficiency in internal control over compliance relating to cash management. Criteria: The Uniform Guidance requires the University to manage grant payments to minimize the time elapsing between the transfer of funds received from the federal government and disbursement by a recipient and/or to draw funds on an as-needed basis within three days before the funds are needed. Statement of Condition: The University withdrew the current year budget amount for one grant for $176,615 before incurring allowable expenses and did not disburse the funds within three days. The University kept the funds in an insured account and used the funds on eligible expenses by June 30, 2023. The internal controls over cash management were not operating effectively. Questioned Costs: Interest earned on the advanced funds during 2023 did not exceed an amount that was necessary to return to the funders. Context: The internal controls over cash management did not prevent, or detect and correct, the University from drawing an advance on a federal award prior to incurring, or within three days of paying for, allowable expenses. There was one grant that had a draw of $176,615 that was not in compliance with the cash management requirement. Cause: The University did not have the proper controls in place to ensure that cash advances were spent on allowable grant expenditures within a timely manner of the draw down of grant funds. Effect: The University was not in compliance with cash management requirements. The University also could have earned interest on the advance that would be necessary to return to the funders. Recommendation: We recommend management revisit its processes and controls over the preparation and review of draw downs to ensure the draw downs are supported by expenses prior to the draw down or funds are disbursed within 3 days of any advance draws. Management’s Response: A desk review of ALN #47.076 National Science Foundation (NSF) occured in August 2023 and identified 17.76% of the current year annual budget amount had been drawn down in advance of expenditures incurred and not fully utilized as indicated in 2 CFR 200.305 Federal Payments. MMU has discontinued the practice of drawing down funds in advance based on the budgeted amount for each year of the project (as prior grants allowed). Instead, MMU will draw down funds based on immediate cash requirements each month of the project after expenditures are incurred, reflected in the general ledger system and reviewed by the Principal Investigator (PI)/Co Principal Investigator (Co-PI) and Senior Accountant. The Business Office has implemented a cash management control as follows: review financial requirements upon grant submission and again when awarded, adjust accounting controls according to grantor requirements, actively participate in monthly review of financial reporting to grantor and document all financial activities as required.
Assistance Listing Number(s), Federal Agency and Program Name: 84.031F and 84.031C; United States Department of Education (ED) , and 47.076; National Science Foundation (NSF), Research and Development Cluster. Finding Type: Noncompliance and significant deficiency in internal control over compliance relating to cash management. Criteria: The Uniform Guidance requires the University to manage grant payments to minimize the time elapsing between the transfer of funds received from the federal government and disbursement by a recipient and/or to draw funds on an as-needed basis within three days before the funds are needed. Statement of Condition: The University withdrew the current year budget amount for one grant for $176,615 before incurring allowable expenses and did not disburse the funds within three days. The University kept the funds in an insured account and used the funds on eligible expenses by June 30, 2023. The internal controls over cash management were not operating effectively. Questioned Costs: Interest earned on the advanced funds during 2023 did not exceed an amount that was necessary to return to the funders. Context: The internal controls over cash management did not prevent, or detect and correct, the University from drawing an advance on a federal award prior to incurring, or within three days of paying for, allowable expenses. There was one grant that had a draw of $176,615 that was not in compliance with the cash management requirement. Cause: The University did not have the proper controls in place to ensure that cash advances were spent on allowable grant expenditures within a timely manner of the draw down of grant funds. Effect: The University was not in compliance with cash management requirements. The University also could have earned interest on the advance that would be necessary to return to the funders. Recommendation: We recommend management revisit its processes and controls over the preparation and review of draw downs to ensure the draw downs are supported by expenses prior to the draw down or funds are disbursed within 3 days of any advance draws. Management’s Response: A desk review of ALN #47.076 National Science Foundation (NSF) occured in August 2023 and identified 17.76% of the current year annual budget amount had been drawn down in advance of expenditures incurred and not fully utilized as indicated in 2 CFR 200.305 Federal Payments. MMU has discontinued the practice of drawing down funds in advance based on the budgeted amount for each year of the project (as prior grants allowed). Instead, MMU will draw down funds based on immediate cash requirements each month of the project after expenditures are incurred, reflected in the general ledger system and reviewed by the Principal Investigator (PI)/Co Principal Investigator (Co-PI) and Senior Accountant. The Business Office has implemented a cash management control as follows: review financial requirements upon grant submission and again when awarded, adjust accounting controls according to grantor requirements, actively participate in monthly review of financial reporting to grantor and document all financial activities as required.
Assistance Listing Number(s), Federal Agency and Program Name: 84.031F and 84.031C; United States Department of Education (ED) , and 47.076; National Science Foundation (NSF), Research and Development Cluster. Finding Type: Noncompliance and significant deficiency in internal control over compliance relating to cash management. Criteria: The Uniform Guidance requires the University to manage grant payments to minimize the time elapsing between the transfer of funds received from the federal government and disbursement by a recipient and/or to draw funds on an as-needed basis within three days before the funds are needed. Statement of Condition: The University withdrew the current year budget amount for one grant for $176,615 before incurring allowable expenses and did not disburse the funds within three days. The University kept the funds in an insured account and used the funds on eligible expenses by June 30, 2023. The internal controls over cash management were not operating effectively. Questioned Costs: Interest earned on the advanced funds during 2023 did not exceed an amount that was necessary to return to the funders. Context: The internal controls over cash management did not prevent, or detect and correct, the University from drawing an advance on a federal award prior to incurring, or within three days of paying for, allowable expenses. There was one grant that had a draw of $176,615 that was not in compliance with the cash management requirement. Cause: The University did not have the proper controls in place to ensure that cash advances were spent on allowable grant expenditures within a timely manner of the draw down of grant funds. Effect: The University was not in compliance with cash management requirements. The University also could have earned interest on the advance that would be necessary to return to the funders. Recommendation: We recommend management revisit its processes and controls over the preparation and review of draw downs to ensure the draw downs are supported by expenses prior to the draw down or funds are disbursed within 3 days of any advance draws. Management’s Response: A desk review of ALN #47.076 National Science Foundation (NSF) occured in August 2023 and identified 17.76% of the current year annual budget amount had been drawn down in advance of expenditures incurred and not fully utilized as indicated in 2 CFR 200.305 Federal Payments. MMU has discontinued the practice of drawing down funds in advance based on the budgeted amount for each year of the project (as prior grants allowed). Instead, MMU will draw down funds based on immediate cash requirements each month of the project after expenditures are incurred, reflected in the general ledger system and reviewed by the Principal Investigator (PI)/Co Principal Investigator (Co-PI) and Senior Accountant. The Business Office has implemented a cash management control as follows: review financial requirements upon grant submission and again when awarded, adjust accounting controls according to grantor requirements, actively participate in monthly review of financial reporting to grantor and document all financial activities as required.
FA 2023-001 Improve Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Cash Management Program Income Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: COVID-19 – 84.425U – American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425U210012 Questioned Costs: $309,623 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background Information: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $18,867,709 were expended and reported on the Clarke County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2023. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to 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 200.303 – Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 – Factors Affecting Allowability of Costs state that “costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity… (g) Be adequately documented…” In addition, provisions included in the Uniform Guidance, Section 202.403 – Reasonable Costs state that “a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm’s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award… (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award’s cost.” Furthermore, provisions included in the Uniform Guidance, Section 200.305(b)(5) state that “To the extent available, the non-Federal entity must disburse funds available from program income… before requesting additional cash payments.” Lastly, provisions included in the Uniform Guidance, Section 200.307(e)(1) state that “ordinarily program income must be deducted from total allowable costs to determine the net allowable costs. Program income must be used for current costs unless the Federal awarding agency authorizes otherwise…” Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed that ESSER funds were utilized to cover after-school program expenditures that exceeded net allowable costs. The School District incurred $1,765,203 in expenditures and received $913,744 in program income related to the after-school program. Based upon this activity, the net allowable costs that could have been funded by the ESSER program totaled $851,459; however, the School District received $1,161,082 in ESSER funding for this purpose during the period under review. Therefore, expenditures totaling $309,623 were deemed unallowable for the ESSER program, and it was noted that excessive cash drawdowns in this same amount were made. Questioned Costs: Known questioned costs of $309,623 identified for unallowable expenditures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per management personnel, schools experienced a significant shortfall in revenue with the closure of schools due to the pandemic. By covering the after-school program payroll with ESSER funds, the School District was attempting to reestablish a fund balance for their after-school program, which should be self-sustaining, and was unaware that they could not use ESSER funds to accomplish this. Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are allowable and program income is expended prior to requesting additional cash payments from federal funds. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with applicable policies and procedures. Views of Responsible Officials: We concur with this finding.