2024-002 Drawdown Tracking Compliance Requirement Cash Management Finding Type Significant Deficiency in Internal Controls and Noncompliance Federal Agency US Department of Education ALN 84.031 Federal Program Higher Education Institutional Aid ALN 84.042A Federal Program TRIO Cluster Program Criteria 2 CFR § 200.305 (b) – Federal Payment ..... Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition Higher Education Institutional Aid From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Twenty-four instances where the three-day rule was exceeded. Five instances where the specific drawdown related to the disbursement could not be identified. TRIO Cluster Programs From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Fourteen instances where the three-day rule was exceeded. Three instances where the specific drawdown related to the disbursement could not be identified. Cause Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown. Effect Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding. Questioned Costs None. Recommendation We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices. Views of responsible official Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking Compliance Requirement Cash Management Finding Type Significant Deficiency in Internal Controls and Noncompliance Federal Agency US Department of Education ALN 84.031 Federal Program Higher Education Institutional Aid ALN 84.042A Federal Program TRIO Cluster Program Criteria 2 CFR § 200.305 (b) – Federal Payment ..... Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition Higher Education Institutional Aid From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Twenty-four instances where the three-day rule was exceeded. Five instances where the specific drawdown related to the disbursement could not be identified. TRIO Cluster Programs From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Fourteen instances where the three-day rule was exceeded. Three instances where the specific drawdown related to the disbursement could not be identified. Cause Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown. Effect Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding. Questioned Costs None. Recommendation We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices. Views of responsible official Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking Compliance Requirement Cash Management Finding Type Significant Deficiency in Internal Controls and Noncompliance Federal Agency US Department of Education ALN 84.031 Federal Program Higher Education Institutional Aid ALN 84.042A Federal Program TRIO Cluster Program Criteria 2 CFR § 200.305 (b) – Federal Payment ..... Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition Higher Education Institutional Aid From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Twenty-four instances where the three-day rule was exceeded. Five instances where the specific drawdown related to the disbursement could not be identified. TRIO Cluster Programs From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Fourteen instances where the three-day rule was exceeded. Three instances where the specific drawdown related to the disbursement could not be identified. Cause Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown. Effect Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding. Questioned Costs None. Recommendation We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices. Views of responsible official Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking Compliance Requirement Cash Management Finding Type Significant Deficiency in Internal Controls and Noncompliance Federal Agency US Department of Education ALN 84.031 Federal Program Higher Education Institutional Aid ALN 84.042A Federal Program TRIO Cluster Program Criteria 2 CFR § 200.305 (b) – Federal Payment ..... Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition Higher Education Institutional Aid From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Twenty-four instances where the three-day rule was exceeded. Five instances where the specific drawdown related to the disbursement could not be identified. TRIO Cluster Programs From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Fourteen instances where the three-day rule was exceeded. Three instances where the specific drawdown related to the disbursement could not be identified. Cause Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown. Effect Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding. Questioned Costs None. Recommendation We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices. Views of responsible official Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking Compliance Requirement Cash Management Finding Type Significant Deficiency in Internal Controls and Noncompliance Federal Agency US Department of Education ALN 84.031 Federal Program Higher Education Institutional Aid ALN 84.042A Federal Program TRIO Cluster Program Criteria 2 CFR § 200.305 (b) – Federal Payment ..... Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition Higher Education Institutional Aid From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Twenty-four instances where the three-day rule was exceeded. Five instances where the specific drawdown related to the disbursement could not be identified. TRIO Cluster Programs From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Fourteen instances where the three-day rule was exceeded. Three instances where the specific drawdown related to the disbursement could not be identified. Cause Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown. Effect Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding. Questioned Costs None. Recommendation We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices. Views of responsible official Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking Compliance Requirement Cash Management Finding Type Significant Deficiency in Internal Controls and Noncompliance Federal Agency US Department of Education ALN 84.031 Federal Program Higher Education Institutional Aid ALN 84.042A Federal Program TRIO Cluster Program Criteria 2 CFR § 200.305 (b) – Federal Payment ..... Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition Higher Education Institutional Aid From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Twenty-four instances where the three-day rule was exceeded. Five instances where the specific drawdown related to the disbursement could not be identified. TRIO Cluster Programs From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Fourteen instances where the three-day rule was exceeded. Three instances where the specific drawdown related to the disbursement could not be identified. Cause Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown. Effect Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding. Questioned Costs None. Recommendation We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices. Views of responsible official Refer to Corrective Action Plan (Unaudited)
Criteria: Under 2 CFR §200.302(b), §200.303, and §200.305, non-federal entities must establish internal controls over federal awards to ensure proper financial management, allowability of costs, timely and accurate reporting, and proper cash management. Additionally, under GAAP (ASC 958-605), grant revenue should be recognized when allowable costs have been incurred. Documentation and supervisory review are necessary to support revenue recognition and ensure expenditures and drawdowns are accurately reported. Condition: The Organization did not document a monthly reconciliation review process to confirm that federal revenues recorded in the general ledger and federal grant drawdowns were supported by allowable costs incurred. Additionally, there was no evidence of review or reconciliation of annual SF-425 Federal Financial Reports to verify that cumulative drawdowns reconciled to allowable costs and recorded revenue. Cause: The Organization lacked a formal internal control process requiring review and sign-off of the reconciliation of grant expenditures, grant revenue, drawdowns, and SF-425 federal financial reporting. Effect: Inadequate internal controls over allowable costs, cash management, and federal financial reporting increased the risk of improper grant revenue recognition recorded, expenditures not being accurately reported, and unallowable costs being claimed, which could lead to misstatements in the financial statements, Schedule of Expenditures of Federal Awards (SEFA), and required federal reports, and result in noncompliance with Uniform Guidance and GAAP. Questioned Cost: None Recommendation: Implement a documented monthly reconciliation process to verify that federal revenues recorded and drawn down are supported by allowable costs incurred in accordance with grant terms. Include supervisory review of SF-425 reports and supporting schedules to confirm alignment with recorded expenditures and revenues. Reconciliations should be reviewed and signed by the CFO and retained in grant records to ensure compliance with Uniform Guidance and GAAP.
2024-002 Drawdown Tracking Compliance Requirement Cash Management Finding Type Significant Deficiency in Internal Controls and Noncompliance Federal Agency US Department of Education ALN 84.031 Federal Program Higher Education Institutional Aid ALN 84.042A Federal Program TRIO Cluster Program Criteria 2 CFR § 200.305 (b) – Federal Payment ..... Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition Higher Education Institutional Aid From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Twenty-four instances where the three-day rule was exceeded. Five instances where the specific drawdown related to the disbursement could not be identified. TRIO Cluster Programs From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Fourteen instances where the three-day rule was exceeded. Three instances where the specific drawdown related to the disbursement could not be identified. Cause Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown. Effect Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding. Questioned Costs None. Recommendation We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices. Views of responsible official Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking Compliance Requirement Cash Management Finding Type Significant Deficiency in Internal Controls and Noncompliance Federal Agency US Department of Education ALN 84.031 Federal Program Higher Education Institutional Aid ALN 84.042A Federal Program TRIO Cluster Program Criteria 2 CFR § 200.305 (b) – Federal Payment ..... Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition Higher Education Institutional Aid From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Twenty-four instances where the three-day rule was exceeded. Five instances where the specific drawdown related to the disbursement could not be identified. TRIO Cluster Programs From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Fourteen instances where the three-day rule was exceeded. Three instances where the specific drawdown related to the disbursement could not be identified. Cause Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown. Effect Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding. Questioned Costs None. Recommendation We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices. Views of responsible official Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking Compliance Requirement Cash Management Finding Type Significant Deficiency in Internal Controls and Noncompliance Federal Agency US Department of Education ALN 84.031 Federal Program Higher Education Institutional Aid ALN 84.042A Federal Program TRIO Cluster Program Criteria 2 CFR § 200.305 (b) – Federal Payment ..... Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition Higher Education Institutional Aid From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Twenty-four instances where the three-day rule was exceeded. Five instances where the specific drawdown related to the disbursement could not be identified. TRIO Cluster Programs From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Fourteen instances where the three-day rule was exceeded. Three instances where the specific drawdown related to the disbursement could not be identified. Cause Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown. Effect Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding. Questioned Costs None. Recommendation We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices. Views of responsible official Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking Compliance Requirement Cash Management Finding Type Significant Deficiency in Internal Controls and Noncompliance Federal Agency US Department of Education ALN 84.031 Federal Program Higher Education Institutional Aid ALN 84.042A Federal Program TRIO Cluster Program Criteria 2 CFR § 200.305 (b) – Federal Payment ..... Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition Higher Education Institutional Aid From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Twenty-four instances where the three-day rule was exceeded. Five instances where the specific drawdown related to the disbursement could not be identified. TRIO Cluster Programs From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Fourteen instances where the three-day rule was exceeded. Three instances where the specific drawdown related to the disbursement could not be identified. Cause Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown. Effect Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding. Questioned Costs None. Recommendation We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices. Views of responsible official Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking Compliance Requirement Cash Management Finding Type Significant Deficiency in Internal Controls and Noncompliance Federal Agency US Department of Education ALN 84.031 Federal Program Higher Education Institutional Aid ALN 84.042A Federal Program TRIO Cluster Program Criteria 2 CFR § 200.305 (b) – Federal Payment ..... Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition Higher Education Institutional Aid From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Twenty-four instances where the three-day rule was exceeded. Five instances where the specific drawdown related to the disbursement could not be identified. TRIO Cluster Programs From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Fourteen instances where the three-day rule was exceeded. Three instances where the specific drawdown related to the disbursement could not be identified. Cause Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown. Effect Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding. Questioned Costs None. Recommendation We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices. Views of responsible official Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking Compliance Requirement Cash Management Finding Type Significant Deficiency in Internal Controls and Noncompliance Federal Agency US Department of Education ALN 84.031 Federal Program Higher Education Institutional Aid ALN 84.042A Federal Program TRIO Cluster Program Criteria 2 CFR § 200.305 (b) – Federal Payment ..... Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition Higher Education Institutional Aid From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Twenty-four instances where the three-day rule was exceeded. Five instances where the specific drawdown related to the disbursement could not be identified. TRIO Cluster Programs From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Fourteen instances where the three-day rule was exceeded. Three instances where the specific drawdown related to the disbursement could not be identified. Cause Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown. Effect Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding. Questioned Costs None. Recommendation We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices. Views of responsible official Refer to Corrective Action Plan (Unaudited)
2024-002 Drawdown Tracking Compliance Requirement Cash Management Finding Type Significant Deficiency in Internal Controls and Noncompliance Federal Agency US Department of Education ALN 84.031 Federal Program Higher Education Institutional Aid ALN 84.042A Federal Program TRIO Cluster Program Criteria 2 CFR § 200.305 (b) – Federal Payment ..... Payments for recipients and subrecipients other than States. For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition Higher Education Institutional Aid From a sample of sixty-six disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Twenty-four instances where the three-day rule was exceeded. Five instances where the specific drawdown related to the disbursement could not be identified. TRIO Cluster Programs From a sample of thirty-seven disbursements selected to test the three-day rule time elapsing between the transfer of funds from the Federal agency and the disbursement of funds, we identified the following: Fourteen instances where the three-day rule was exceeded. Three instances where the specific drawdown related to the disbursement could not be identified. Cause Lack of policies to control the number of days elapsed between the transfer of Federal funds and the date of the disbursement. The University is not completing and retaining the G5 Cash Summary Form or equivalent document for each drawdown. Effect Misuse of funds, failure to demonstrate timely use of funds, and inadequate cash flow management. These issues could lead to loss of federal funding eligibility, placement on Heightened Cash Monitoring Methods, and penalties. Additionally, there is a risk of overspending or duplicating payments, as well as difficulty detecting errors or fraud. This can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Furthermore, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding. Questioned Costs None. Recommendation We recommend to enhance documentation practices by implementing a system that ensures all disbursements are clearly linked to their corresponding drawdowns. This will help accurately track the time elapsed between fund transfer and disbursement. Utilizing automated financial management systems can further reduce human error and improve compliance by efficiently tracking and linking drawdowns to disbursements. Regular internal audits should be scheduled to review compliance with the three-day rule and other cash management requirements, promptly identifying and correcting discrepancies. Finally, updating cash management policies to include specific procedures for associating drawdowns with disbursements and ensuring these policies are communicated and enforced across the organization will help maintain compliance and enhance overall cash management practices. Views of responsible official Refer to Corrective Action Plan (Unaudited)
Criteria: Under 2 CFR §200.302(b), §200.303, and §200.305, non-federal entities must establish internal controls over federal awards to ensure proper financial management, allowability of costs, timely and accurate reporting, and proper cash management. Additionally, under GAAP (ASC 958-605), grant revenue should be recognized when allowable costs have been incurred. Documentation and supervisory review are necessary to support revenue recognition and ensure expenditures and drawdowns are accurately reported. Condition: The Organization did not document a monthly reconciliation review process to confirm that federal revenues recorded in the general ledger and federal grant drawdowns were supported by allowable costs incurred. Additionally, there was no evidence of review or reconciliation of annual SF-425 Federal Financial Reports to verify that cumulative drawdowns reconciled to allowable costs and recorded revenue. Cause: The Organization lacked a formal internal control process requiring review and sign-off of the reconciliation of grant expenditures, grant revenue, drawdowns, and SF-425 federal financial reporting. Effect: Inadequate internal controls over allowable costs, cash management, and federal financial reporting increased the risk of improper grant revenue recognition recorded, expenditures not being accurately reported, and unallowable costs being claimed, which could lead to misstatements in the financial statements, Schedule of Expenditures of Federal Awards (SEFA), and required federal reports, and result in noncompliance with Uniform Guidance and GAAP. Questioned Cost: None Recommendation: Implement a documented monthly reconciliation process to verify that federal revenues recorded and drawn down are supported by allowable costs incurred in accordance with grant terms. Include supervisory review of SF-425 reports and supporting schedules to confirm alignment with recorded expenditures and revenues. Reconciliations should be reviewed and signed by the CFO and retained in grant records to ensure compliance with Uniform Guidance and GAAP.
Cash Management-Subrecipient Federal Agency: U.S. Federal Government Federal Program Title: Research and Development Cluster Assistance Listing Number: 93.859; 47.074 Federal Award Identification Number and Year: 1R01GM137083 – 2024; 2317969 - 2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(4)). In addition, per the Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Three subrecipient invoices, totaling $29,306, out of 5 tested, totaling $60,038, were not paid within the required 30 days. Questioned costs: None. Cause: Procedures were not in place to ensure subrecipients were paid within 30 days of receipt of the invoices. Effect: Subrecipients did not receive their reimbursement timely. Repeat finding: Yes, 2023-002 Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the Subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Cash Management-Subrecipient Federal Agency: U.S. Federal Government Federal Program Title: Research and Development Cluster Assistance Listing Number: 93.859; 47.074 Federal Award Identification Number and Year: 1R01GM137083 – 2024; 2317969 - 2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(4)). In addition, per the Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Three subrecipient invoices, totaling $29,306, out of 5 tested, totaling $60,038, were not paid within the required 30 days. Questioned costs: None. Cause: Procedures were not in place to ensure subrecipients were paid within 30 days of receipt of the invoices. Effect: Subrecipients did not receive their reimbursement timely. Repeat finding: Yes, 2023-002 Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the Subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
2024-001 EXCESS DRAWDOWN OF FEDERAL FUNDS Federal agency: U.S. Department of Education Federal Program Title & Assistance Listing Number: Extending Equity into the Digital Workforce Projects of Regional and National Significance -84.411B Award Period: 12/15/2021 - 12/15/2025 Type of Finding: Significant Deficiency, Other Non-compliance Compliance Areas: Cash Management, Allowable Costs, and Cost Principles and Reporting Questioned Costs: None Condition During testing of expenditures and manual journal entries for the Extending Equity into the Digital Workforce (EEDW) grant, we identified a duplicate manual journal entry of $129,781. This entry reclassified August and September 2023 General Fund (Fund 27101) expenditures to the EEDW Fund (Fund 25271). While the costs themselves are necessary and reasonable under the grant's objectives, the duplicate entry resulted in the federal fund expenditures being overstated and reimbursed twice, leading to an overdraw of federal funds. The duplicate entry was reversed by the client upon discovery by the auditors. An audit adjustment was made to record the excess cash balance as unearned grant revenue. Additionally, the annual Federal Financial Report for the period ending December 31, 2023, included these expenditures, causing the reported federal disbursements to be overstated by $129,781. Criteria Cash Management: Although 2 CFR 200.305(b)(1) permits the Cooperative to draw funds in advance, the entity utilizes a cost reimbursement approach for Federal funding. This practice ensures that funds are drawn only for immediate cash needs. 2 CFR 200.305(b)(1) Federal payment. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. Cost Principles and Reporting: The application of cost principles is governed by 2 CFR 200.400; specifically (b) the non-Federal entity assumes responsibility for administering Federal funds in a manner consistent with underlying agreements, program objectives, and the terms and conditions of the Federal award. Effect The error resulted in an overstatement of federal revenues and expenditures, leading to excess unearned cash in the fund at year-end and inaccuracies in the financial reports (SF-425) submitted to the federal funding agency. The Cooperative is not in compliance with federal regulations for Cash Management and Cost Principles and Reporting. Cause The allowable expenditures intended to be reclassified from the general fund to the federal fund were processed twice, resulting in a duplicate recording. This error was not detected during regular reconciliations or the financial close and reporting process.
Reference Number: 2024-003 Description: Written Procedures Condition and Criteria: At the beginning of the audit period, the District did not have a Federal Funds Manual in place to document policies and procedures for managing federal awards in compliance 2 CFR 200, Subparts D and E. The Uniform Guidance requires the following written procedures: Written procedures for grant financial management (2 CFR 200.302 and 2 CFR 200.305) Written procurement policy (2 CFR 200.318a) Written procedures for allowable costs (2 CFR 200.403) Written procedures for managing and safeguarding property or equipment acquired with federal funds (2 CFR 200.313) During the course of the audit, the District developed and implemented a Federal Funds Manual to address this deficiency. Cause: There was an administrative oversight of ensuring the District had these written procedures in place. Effect: The absence of a documented Federal Funds Manual increased the risk of noncompliance with federal requirements and ineffective management of federal funds. However, the district’s subsequent implementation of the manual before the audit’s completion reduced this risk. Recommendation: We recommend that the District continue to utilize and periodically review the Federal Funds Manual to ensure it remains comprehensive and up-to-date with changes in federal requirements. Views of Responsible Officials and Corrective Action: See Corrective Action Plan.
Reference Number: 2024-003 Description: Written Procedures Condition and Criteria: At the beginning of the audit period, the District did not have a Federal Funds Manual in place to document policies and procedures for managing federal awards in compliance 2 CFR 200, Subparts D and E. The Uniform Guidance requires the following written procedures: Written procedures for grant financial management (2 CFR 200.302 and 2 CFR 200.305) Written procurement policy (2 CFR 200.318a) Written procedures for allowable costs (2 CFR 200.403) Written procedures for managing and safeguarding property or equipment acquired with federal funds (2 CFR 200.313) During the course of the audit, the District developed and implemented a Federal Funds Manual to address this deficiency. Cause: There was an administrative oversight of ensuring the District had these written procedures in place. Effect: The absence of a documented Federal Funds Manual increased the risk of noncompliance with federal requirements and ineffective management of federal funds. However, the district’s subsequent implementation of the manual before the audit’s completion reduced this risk. Recommendation: We recommend that the District continue to utilize and periodically review the Federal Funds Manual to ensure it remains comprehensive and up-to-date with changes in federal requirements. Views of Responsible Officials and Corrective Action: See Corrective Action Plan.
Reference Number: 2024-003 Description: Written Procedures Condition and Criteria: At the beginning of the audit period, the District did not have a Federal Funds Manual in place to document policies and procedures for managing federal awards in compliance 2 CFR 200, Subparts D and E. The Uniform Guidance requires the following written procedures: Written procedures for grant financial management (2 CFR 200.302 and 2 CFR 200.305) Written procurement policy (2 CFR 200.318a) Written procedures for allowable costs (2 CFR 200.403) Written procedures for managing and safeguarding property or equipment acquired with federal funds (2 CFR 200.313) During the course of the audit, the District developed and implemented a Federal Funds Manual to address this deficiency. Cause: There was an administrative oversight of ensuring the District had these written procedures in place. Effect: The absence of a documented Federal Funds Manual increased the risk of noncompliance with federal requirements and ineffective management of federal funds. However, the district’s subsequent implementation of the manual before the audit’s completion reduced this risk. Recommendation: We recommend that the District continue to utilize and periodically review the Federal Funds Manual to ensure it remains comprehensive and up-to-date with changes in federal requirements. Views of Responsible Officials and Corrective Action: See Corrective Action Plan.
Finding 2024-001 – Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Cluster Assistance Listing Number: 93.224 & 93.527 Federal Award Identification Number: H80CS00725-22-03 & H80CS00725-23-00 Award Periods: June 1, 2023 – May 31, 2024 & June 1, 2024 – May 31, 2025 Criteria: CFR § 200.303 Internal controls states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Furthermore, CFR § 200.305(b) indicates that the non-Federal entity should minimize the time lapsing between the transfer of funds from the Federal agency and the disbursement of funds by the recipient. Condition: The Organization did not maintain documentation to support the performance of its internal control related to the review and approval of a drawdown request. Questioned Costs: None. Context: This condition occurred in one of the five drawdowns selected for testing. Cause: Turnover within the accounting department. Effect: Unauthorized drawdowns could lead to amounts being drawn in excess of the expenses incurred and charged to a federal grant. Repeat Finding: No. Recommendation: We recommend that management reinforce the current internal control over drawdowns and ensure that when turnover happens, the appropriate employee responsibilities are reassigned. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-001 – Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Cluster Assistance Listing Number: 93.224 & 93.527 Federal Award Identification Number: H80CS00725-22-03 & H80CS00725-23-00 Award Periods: June 1, 2023 – May 31, 2024 & June 1, 2024 – May 31, 2025 Criteria: CFR § 200.303 Internal controls states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Furthermore, CFR § 200.305(b) indicates that the non-Federal entity should minimize the time lapsing between the transfer of funds from the Federal agency and the disbursement of funds by the recipient. Condition: The Organization did not maintain documentation to support the performance of its internal control related to the review and approval of a drawdown request. Questioned Costs: None. Context: This condition occurred in one of the five drawdowns selected for testing. Cause: Turnover within the accounting department. Effect: Unauthorized drawdowns could lead to amounts being drawn in excess of the expenses incurred and charged to a federal grant. Repeat Finding: No. Recommendation: We recommend that management reinforce the current internal control over drawdowns and ensure that when turnover happens, the appropriate employee responsibilities are reassigned. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2024-001 – Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Cluster Assistance Listing Number: 93.224 & 93.527 Federal Award Identification Number: H80CS00725-22-03 & H80CS00725-23-00 Award Periods: June 1, 2023 – May 31, 2024 & June 1, 2024 – May 31, 2025 Criteria: CFR § 200.303 Internal controls states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Furthermore, CFR § 200.305(b) indicates that the non-Federal entity should minimize the time lapsing between the transfer of funds from the Federal agency and the disbursement of funds by the recipient. Condition: The Organization did not maintain documentation to support the performance of its internal control related to the review and approval of a drawdown request. Questioned Costs: None. Context: This condition occurred in one of the five drawdowns selected for testing. Cause: Turnover within the accounting department. Effect: Unauthorized drawdowns could lead to amounts being drawn in excess of the expenses incurred and charged to a federal grant. Repeat Finding: No. Recommendation: We recommend that management reinforce the current internal control over drawdowns and ensure that when turnover happens, the appropriate employee responsibilities are reassigned. Views of Responsible Officials: There is no disagreement with the audit finding.
Criteria: 2 CFR 200.305(b) states for non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Condition: In the current fiscal year, the Council received new federal money to provide teen pregnancy prevention services. In order to carry out those services, the Council enters into sub-awards with providers throughout its service territory. Providers submit their invoices to the Council monthly, and the Council submits a request for payment to the grantor for reimbursement. For services provided in June, the Council submitted the request but did not disburse the funds to the providers timely as to minimize the time between the recipient of the grant funds and the payment to the provider. Questioned Costs: None. Context: The Council provided services under a grant received directly from the U.S. Department of Health and Human Services. In order to provide the services, sub-awards are made with providers within the Council’s service territory. Providers were to be paid based off the invoices submitted to the Council. The Council submits a request for payment to the U.S. Department of Health and Human Services and once the funds are received, the Council is to pay its providers in a timely manner. Cause: Due to the program being new, the Council’s payment process has not been updated appropriately to ensure timely payment each and every month. Effect: The providers were not paid timely for services provided in June of 2024. Repeat Finding: This was not a repeat finding. Recommendation: We recommend updates in the payment process to ensure that all providers are paid timely after receipt of grant funds. Management Response: FHCCP acknowledges the finding and has taken immediate corrective action to ensure this issue does not recur. We have established a streamlined process for timely disbursement of funds to providers upon receipt of grant funds. Additionally, we have conducted a training session for staff involved in the payment process to ensure they are fully aware of the new procedures and timelines. A monitoring system has also been implemented to track the timeliness of payments and address any delays promptly. We are confident that these steps will prevent any future delays in payments to our providers. FHCCP remains committed to maintaining compliance with all grant requirements and ensuring the efficient and effective use of federal funds.
2024-003: Material Weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: Employment Services Cluster (ALN 17.207/17.801) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The total amount of funds overdrawn as of year-end totaled $173,888. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding.
2024-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The total amount of funds overdrawn as of year-end totaled $199,778. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding.
Assistance Listing Number, Federal Agency, and Program Name - 84.007, 84.033, 84.063, 84.268; U.S. Department of Education; Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Federal Award Identification Number and Year - P007A236053, P033A236053, P063P232857, P268K242857; 2023-2024 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - In accordance with 2 CFR 200.302(b)(6), the College must establish written procedures to implement the requirements of 200.305 (federal payment), which outlines cash management requirements. Condition - As the College does not have a written cash management policy related to federal payments/awards, there was a lack of internal controls in place to ensure that this compliance requirement is met. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - The College does not have a written cash management policy related to federal payments/awards. Cause and Effect - As there is no control established to ensure this written policy is in place, the College is not in compliance with 2 CFR 200.302(b)(6). Recommendation - We recommend that the College establish a written cash management policy related to federal payments/awards and that controls are implemented to ensure that it is updated as necessary. Views of Responsible Officials and Planned Corrective Actions - In accordance with 2 CFR 200.302(b)(6), the College will establish a written cash management policy, including written procedures related to federal payments/awards, in order to implement the requirements of 200.305.
Assistance Listing Number, Federal Agency, and Program Name - 84.007, 84.033, 84.063, 84.268; U.S. Department of Education; Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Federal Award Identification Number and Year - P007A236053, P033A236053, P063P232857, P268K242857; 2023-2024 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - In accordance with 2 CFR 200.302(b)(6), the College must establish written procedures to implement the requirements of 200.305 (federal payment), which outlines cash management requirements. Condition - As the College does not have a written cash management policy related to federal payments/awards, there was a lack of internal controls in place to ensure that this compliance requirement is met. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - The College does not have a written cash management policy related to federal payments/awards. Cause and Effect - As there is no control established to ensure this written policy is in place, the College is not in compliance with 2 CFR 200.302(b)(6). Recommendation - We recommend that the College establish a written cash management policy related to federal payments/awards and that controls are implemented to ensure that it is updated as necessary. Views of Responsible Officials and Planned Corrective Actions - In accordance with 2 CFR 200.302(b)(6), the College will establish a written cash management policy, including written procedures related to federal payments/awards, in order to implement the requirements of 200.305.
Assistance Listing Number, Federal Agency, and Program Name - 84.007, 84.033, 84.063, 84.268; U.S. Department of Education; Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Federal Award Identification Number and Year - P007A236053, P033A236053, P063P232857, P268K242857; 2023-2024 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - In accordance with 2 CFR 200.302(b)(6), the College must establish written procedures to implement the requirements of 200.305 (federal payment), which outlines cash management requirements. Condition - As the College does not have a written cash management policy related to federal payments/awards, there was a lack of internal controls in place to ensure that this compliance requirement is met. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - The College does not have a written cash management policy related to federal payments/awards. Cause and Effect - As there is no control established to ensure this written policy is in place, the College is not in compliance with 2 CFR 200.302(b)(6). Recommendation - We recommend that the College establish a written cash management policy related to federal payments/awards and that controls are implemented to ensure that it is updated as necessary. Views of Responsible Officials and Planned Corrective Actions - In accordance with 2 CFR 200.302(b)(6), the College will establish a written cash management policy, including written procedures related to federal payments/awards, in order to implement the requirements of 200.305.
Assistance Listing Number, Federal Agency, and Program Name - 84.007, 84.033, 84.063, 84.268; U.S. Department of Education; Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Federal Award Identification Number and Year - P007A236053, P033A236053, P063P232857, P268K242857; 2023-2024 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - In accordance with 2 CFR 200.302(b)(6), the College must establish written procedures to implement the requirements of 200.305 (federal payment), which outlines cash management requirements. Condition - As the College does not have a written cash management policy related to federal payments/awards, there was a lack of internal controls in place to ensure that this compliance requirement is met. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - The College does not have a written cash management policy related to federal payments/awards. Cause and Effect - As there is no control established to ensure this written policy is in place, the College is not in compliance with 2 CFR 200.302(b)(6). Recommendation - We recommend that the College establish a written cash management policy related to federal payments/awards and that controls are implemented to ensure that it is updated as necessary. Views of Responsible Officials and Planned Corrective Actions - In accordance with 2 CFR 200.302(b)(6), the College will establish a written cash management policy, including written procedures related to federal payments/awards, in order to implement the requirements of 200.305.
Federal Program: U.S. Department of Justice AL #16.710. Federal Award Year: 2024. Criteria: When non-federal entities are funded under the reimbursement method, expenditures need to be incurred prior to the date of the reimbursement request (2 CFR section 200.305(b)(3)). Condition: During our testing of cash management procedures, it was noted that the first draw down request was for an amount greater than the amount of expenditures that had been incurred as of the draw down date. The entire amount of requested funds was paid to the District. Cause: Lack of internal controls over the draw down process. Effect: The District received federal funds in excess of what is allowed under the program. Questioned Costs: None. Repeat Finding: Not a repeat finding. Recommendations: We recommend the District review their procedures over draw requests to ensure that the appropriate funds are being requested. Views of Responsible Officials and Planned Corrective Actions: Management recognizes the deficiency and plans to implement the auditor's recommendation.The District has returned all overdrawn funds to the Federal agency.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(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 payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(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 payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(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 payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(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 payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(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 payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(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 payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(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 payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(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 payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.