Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabilization Fund Federal Award Identification Number and Year - P425E203325, 2020; P425F202751, 2020; P425M200930, 2020 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-001 Criteria - The College must minimize the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds, as outlined in 2 CFR Section 200.305(b). Condition - The College drew down the full amount of each award prior to the funds being disbursed to students or used for allowable expenditures, including lost revenue. Questioned Costs - There were no questioned costs identified. Context - In November 2021, the College drew down $5,882,052 for the student aid portion and $5,622,717 for the institutional aid portion. In July 2022, the College drew down $929,887 for the Strengthening Institutions Program (SIP). In each case, the College did not spend the funds within the required time frame following the cash management rules under 2 CFR Section 200.305(b). Cause and Effect - The College was not aware that cash management requirements under the Uniform Guidance applied to these programs, which resulted in an excess of funds drawndown. Recommendation - We recommend the College implement a process to minimize the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds. Views of Responsible Officials and Corrective Action Plan - There is no more HEERF or federal stimulus funding to be drawn down moving forward. However, if there is in the future,the College will follow the three-day drawdown rules for cash disbursements.
Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabilization Fund Federal Award Identification Number and Year - P425E203325, 2020; P425F202751, 2020; P425M200930, 2020 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-001 Criteria - The College must minimize the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds, as outlined in 2 CFR Section 200.305(b). Condition - The College drew down the full amount of each award prior to the funds being disbursed to students or used for allowable expenditures, including lost revenue. Questioned Costs - There were no questioned costs identified. Context - In November 2021, the College drew down $5,882,052 for the student aid portion and $5,622,717 for the institutional aid portion. In July 2022, the College drew down $929,887 for the Strengthening Institutions Program (SIP). In each case, the College did not spend the funds within the required time frame following the cash management rules under 2 CFR Section 200.305(b). Cause and Effect - The College was not aware that cash management requirements under the Uniform Guidance applied to these programs, which resulted in an excess of funds drawndown. Recommendation - We recommend the College implement a process to minimize the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds. Views of Responsible Officials and Corrective Action Plan - There is no more HEERF or federal stimulus funding to be drawn down moving forward. However, if there is in the future,the College will follow the three-day drawdown rules for cash disbursements.
2023-001 ALLOWABLE COST, CASH MANAGEMENT, AND PERIOD OF PERFORMANCE - SIGNIFICANT DEFICIENCY Federal Program Unaccompanied Alien Children Program ALN 93.676 Criteria Part 3 of the Compliance Supplement indicates non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). Part 3 of the Compliance Supplement indicates a non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition/Cause In July 2022, the Home requested reimbursement and received funding to cover costs that had not yet been incurred or paid for as of June 30, 2023. Effect The Home was reimbursed for costs that were not incurred during the budget period. Additionally, the Home has held onto grant funds for twelve plus months. Questioned Costs Known questioned costs are $52,841. Context The Home budgeted to have new fire alarms installed in the cottages during the July 1, 2021 - June 30, 2022 grant budget period. Due to supply chain issues and labor shortages the alarms were not installed until the Fall of 2023 at which time the Home paid the contractor. Repeat Finding No. Recommendation We recommend the Home contact the funding agency to inquire about returning the funds and any interest earned. We also recommend that the Home revisit and strengthen internal controls over allowable activities, allowable costs, cash management, and period of availability related to grant programs. Management Response See corrective action plan included in this report package.
2023–034 SUBRECIPIENT CASH MANAGEMENT Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) 93.323/COVID-19 93.323, Grant Award 6NU50CK000551-01-05, Grant Award 5NU50CK000551-C2-00, Grant Award 6NU50CK000551-02-01, Grant Award 6NU50CK000551-02-02, Grant Award 6NU50CK000551-03-05, Grant Award 6NU50CK000551-03-02, Grant Award 6NU50CK000551-02-04, Grant Award 6NU50CK000551-02-08, Grant Award 6NU50CK000551-02-06, Grant Award 6NU50CK000551-03-01, Grant Award 6NU50CK000551-01-07, Grant Award 6NU50CK000551-02-03, Grant Award 6NU50CK000551-01-06, Grant Award 5NU50CK000551-04-00, Grant Award 6NU50CK000551-04-02, Grant Award 6NU50CK000551-04-04 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.305(b)(1) requires that the non-federal entity 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 as required by the applicable cash management requirements in the federal award to the recipient.” Per DHHR policy, the Spending Unit shall limit cash advances to a subrecipient to the minimum amounts needed and be timed in accordance with the actual, immediate cash requirements of the subrecipient for carrying out the purpose of the approved program or project. The timing and amount of cash advances shall be as close as is administratively feasible to the actual disbursements by the subrecipient for direct program or project costs and the proportionate share of any allowable indirect costs. Condition: During our testing of Epidemiology and Laboratory Capacity for Infectious Diseases, the West Virginia Department of Health and Human Resources (DHHR) was unable to provide adequate documentation supporting why a subrecipient drawdown was approved for payment for 1 of the 36 drawdowns selected for testing. The supporting documentation for the draw down showed less expenses than the amount that had been drawn down to date on the grants and also showed the subrecipient appeared to have adequate cash balances on hand at the time of the request. Cause: Supporting documentation was not retained to demonstrate cash advances to the subrecipient represented the minimum amount needed for actual and immediate cash requirements of the subrecipient for carrying out the purpose of the program. Effect or Potential Effect: The cash remitted to the subrecipient may not be accurate and may be in excess of the subrecipients actual and immediate cash requirements for carrying out the purpose of the program. Questioned Costs: $77,063 Context: The total subrecipient drawdowns selected for testing was $1,879,150. The total amount of subrecipient drawdowns for the Epidemiology program during FY23 was $7,478,038. Identification as a Repeat Finding: This is not a repeat finding from the prior year. Recommendation: We recommend that DHHR establish policies and procedures requiring documentation from subrecipients substantiating that the amount of a drawdown is appropriate based on the expenditures through the request date so that the reconciliation preformed for the related drawdown is sufficient to determine that the drawdown is appropriate and excess cash is not remitted to the subrecipient. View of Responsible Officials: Management concurs with the findings and has developed a plan to correct the finding.
2023–034 SUBRECIPIENT CASH MANAGEMENT Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) 93.323/COVID-19 93.323, Grant Award 6NU50CK000551-01-05, Grant Award 5NU50CK000551-C2-00, Grant Award 6NU50CK000551-02-01, Grant Award 6NU50CK000551-02-02, Grant Award 6NU50CK000551-03-05, Grant Award 6NU50CK000551-03-02, Grant Award 6NU50CK000551-02-04, Grant Award 6NU50CK000551-02-08, Grant Award 6NU50CK000551-02-06, Grant Award 6NU50CK000551-03-01, Grant Award 6NU50CK000551-01-07, Grant Award 6NU50CK000551-02-03, Grant Award 6NU50CK000551-01-06, Grant Award 5NU50CK000551-04-00, Grant Award 6NU50CK000551-04-02, Grant Award 6NU50CK000551-04-04 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.305(b)(1) requires that the non-federal entity 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 as required by the applicable cash management requirements in the federal award to the recipient.” Per DHHR policy, the Spending Unit shall limit cash advances to a subrecipient to the minimum amounts needed and be timed in accordance with the actual, immediate cash requirements of the subrecipient for carrying out the purpose of the approved program or project. The timing and amount of cash advances shall be as close as is administratively feasible to the actual disbursements by the subrecipient for direct program or project costs and the proportionate share of any allowable indirect costs. Condition: During our testing of Epidemiology and Laboratory Capacity for Infectious Diseases, the West Virginia Department of Health and Human Resources (DHHR) was unable to provide adequate documentation supporting why a subrecipient drawdown was approved for payment for 1 of the 36 drawdowns selected for testing. The supporting documentation for the draw down showed less expenses than the amount that had been drawn down to date on the grants and also showed the subrecipient appeared to have adequate cash balances on hand at the time of the request. Cause: Supporting documentation was not retained to demonstrate cash advances to the subrecipient represented the minimum amount needed for actual and immediate cash requirements of the subrecipient for carrying out the purpose of the program. Effect or Potential Effect: The cash remitted to the subrecipient may not be accurate and may be in excess of the subrecipients actual and immediate cash requirements for carrying out the purpose of the program. Questioned Costs: $77,063 Context: The total subrecipient drawdowns selected for testing was $1,879,150. The total amount of subrecipient drawdowns for the Epidemiology program during FY23 was $7,478,038. Identification as a Repeat Finding: This is not a repeat finding from the prior year. Recommendation: We recommend that DHHR establish policies and procedures requiring documentation from subrecipients substantiating that the amount of a drawdown is appropriate based on the expenditures through the request date so that the reconciliation preformed for the related drawdown is sufficient to determine that the drawdown is appropriate and excess cash is not remitted to the subrecipient. View of Responsible Officials: Management concurs with the findings and has developed a plan to correct the finding.
2023–052 SUBRECIPIENT CASH MANAGEMENT Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Opioid STR 93.788, Grant Award 1H79TI085744, Grant Award 5H79TI083313, Grant Award 1H79TI083313, Grant Award 6H79TI083313 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be following guidance in “Standards for Internal Control in the Federal Government” issued by the comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.305(b)(1) requires that the non-federal entity 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 as required by the applicable cash management requirements in the federal award to the recipient.” Per DHHR policy, the Spending Unit shall limit cash advances to a subrecipient to the minimum amounts needed and be timed in accordance with the actual, immediate cash requirements of the subrecipient for carrying out the purpose of the approved program or project. The timing and amount of cash advances shall be as close as is administratively feasible to the actual disbursements by the subrecipient for direct program or project costs and the proportionate share of any allowable indirect costs. Condition: During testing of the State Targeted Response to the Opioid Crisis Grants, for 3 of the 40 disbursements selected for testing the approval of the reconciliation of grantee drawdowns and expenses was not reviewed prior to the payment of the subrecipient invoice. Further for 1 of the 40 disbursements selected for testing, information supporting why the subrecipient drawdown was approved for payment was not adequate. Supporting information indicates the grantee had excess cash balances on hand prior to the draw and there was no formal documentation of a program manager’s justification to allow the draw therefore the state was not minimizing the time between the transfer of funds to the subrecipient and the subrecipient’s expenditure of the funds. Cause: Internal controls are not operating effectively surrounding the approval of subrecipient cash disbursements. Supporting documentation was not retained to demonstrate cash advances to the subrecipient represented the minimum amount needed for actual and immediate cash requirements of the subrecipient for carrying out the purpose of the program. Effect or Potential Effect: The cash remitted to the subrecipient may not be accurate and may be in excess of the subrecipients actual and immediate cash requirements for carrying out the purpose of the program. Questioned Costs: $188,484, Opioid STR 93.788 Context: The total subrecipient drawdowns selected for testing was $8,073,637. The total amount of subrecipient drawdowns for the Opioid STR program was $32,972,268 for the year ended June 30, 2023. Identification as a Repeat Finding: Prior Year Finding 2022–038 Recommendation: We recommend that DHHR establish policies and procedures requiring documentation from subrecipients substantiating that the amount of a drawdown is appropriate based on the expenditures through the request date so that the reconciliation preformed for the related drawdown is sufficient to determine that the drawdown is appropriate and excess cash is not remitted to the subrecipient. Views of Responsible Officials: Management concurs with the findings and has developed a plan to correct the finding.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 20.232, U.S. Department of Transportation, Commercial Driver's License Program Implementation Grant - 93.350, U.S. Department of Health and Human Services, National Center for Advancing Translational Sciences - 93.279, U.S. Department of Health and Human Services, Drug Abuse and Addiction Research Programs - 93.853, U.S. Department of Health and Human Services, Extramural Research Programs in the Neurosciences and Neurological Disorders - 93.866, U.S. Department of Health and Human Services, Aging Research Non-Research and Development Cluster: - 17.268, Department of Labor, H-1B Job Training Federal Award Identification Number and Year - Research and Development Cluster: - 20.323 - FM-CDL-0435-20-01-00 - 93.350 - UTR001425B - 93.279 - OSU SPC-1000006389 UM1DA; UDA013732E - 93.853 - SUBK00007313 SLEEP SMART; UNS110772A - 93.866 - RAG072592A 17.268: HG-33044-19-60-A-39, 2019 Pass-through Entity - 93.279 - The Ohio State University; 93.853 - University of Michigan Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a payment within 30 calendar days after receipt of the billing unless the federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition - Out of 28 payments to subrecipients that were tested, 12 were made after the 30-calendar-day requirement, 10 and 2 from the R&D Cluster and ALN 17.268, respectively. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related solely to timeliness of payments. Context - In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 39 - 242 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - The University does have formal general accounts payable and cash disbursement processes in place; however, there are no specific controls in place to ensure that subrecipients are paid within the 30-day requirement. Although all of the payments were ultimately made, the lack of controls resulted in several late payments. Recommendation - The University should implement a control to ensure that payments are made within the required time frame. Views of Responsible Officials and Corrective Action Plan - Accounts payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expenditure. For federal award expenditures, accounts payable will manually change the payment terms to 30 calendar days or less to ensure compliance. Periodically, accounts payable will review open federal award payables to verify payment terms have been properly set for the 30-day compliance requirement. The Controller’s and Accounts Payable offices will also explore creating a more efficient long-term solution, whereby the 30-day terms could be automatically set during the purchase order creation process. This would eliminate any manual updates to the payment terms by accounts payable personnel. The Sponsored Research Services Accounting Office will send reminders to all college business officers and principal investigators (PIs) to highlight the need for prompt review and approval of federal award invoices. This language will be incorporated into the SRS Best Grant Practices training classes, as well as the University’s fundamentals of sponsored administration training courses.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 20.232, U.S. Department of Transportation, Commercial Driver's License Program Implementation Grant - 93.350, U.S. Department of Health and Human Services, National Center for Advancing Translational Sciences - 93.279, U.S. Department of Health and Human Services, Drug Abuse and Addiction Research Programs - 93.853, U.S. Department of Health and Human Services, Extramural Research Programs in the Neurosciences and Neurological Disorders - 93.866, U.S. Department of Health and Human Services, Aging Research Non-Research and Development Cluster: - 17.268, Department of Labor, H-1B Job Training Federal Award Identification Number and Year - Research and Development Cluster: - 20.323 - FM-CDL-0435-20-01-00 - 93.350 - UTR001425B - 93.279 - OSU SPC-1000006389 UM1DA; UDA013732E - 93.853 - SUBK00007313 SLEEP SMART; UNS110772A - 93.866 - RAG072592A 17.268: HG-33044-19-60-A-39, 2019 Pass-through Entity - 93.279 - The Ohio State University; 93.853 - University of Michigan Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a payment within 30 calendar days after receipt of the billing unless the federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition - Out of 28 payments to subrecipients that were tested, 12 were made after the 30-calendar-day requirement, 10 and 2 from the R&D Cluster and ALN 17.268, respectively. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related solely to timeliness of payments. Context - In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 39 - 242 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - The University does have formal general accounts payable and cash disbursement processes in place; however, there are no specific controls in place to ensure that subrecipients are paid within the 30-day requirement. Although all of the payments were ultimately made, the lack of controls resulted in several late payments. Recommendation - The University should implement a control to ensure that payments are made within the required time frame. Views of Responsible Officials and Corrective Action Plan - Accounts payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expenditure. For federal award expenditures, accounts payable will manually change the payment terms to 30 calendar days or less to ensure compliance. Periodically, accounts payable will review open federal award payables to verify payment terms have been properly set for the 30-day compliance requirement. The Controller’s and Accounts Payable offices will also explore creating a more efficient long-term solution, whereby the 30-day terms could be automatically set during the purchase order creation process. This would eliminate any manual updates to the payment terms by accounts payable personnel. The Sponsored Research Services Accounting Office will send reminders to all college business officers and principal investigators (PIs) to highlight the need for prompt review and approval of federal award invoices. This language will be incorporated into the SRS Best Grant Practices training classes, as well as the University’s fundamentals of sponsored administration training courses.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 20.232, U.S. Department of Transportation, Commercial Driver's License Program Implementation Grant - 93.350, U.S. Department of Health and Human Services, National Center for Advancing Translational Sciences - 93.279, U.S. Department of Health and Human Services, Drug Abuse and Addiction Research Programs - 93.853, U.S. Department of Health and Human Services, Extramural Research Programs in the Neurosciences and Neurological Disorders - 93.866, U.S. Department of Health and Human Services, Aging Research Non-Research and Development Cluster: - 17.268, Department of Labor, H-1B Job Training Federal Award Identification Number and Year - Research and Development Cluster: - 20.323 - FM-CDL-0435-20-01-00 - 93.350 - UTR001425B - 93.279 - OSU SPC-1000006389 UM1DA; UDA013732E - 93.853 - SUBK00007313 SLEEP SMART; UNS110772A - 93.866 - RAG072592A 17.268: HG-33044-19-60-A-39, 2019 Pass-through Entity - 93.279 - The Ohio State University; 93.853 - University of Michigan Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a payment within 30 calendar days after receipt of the billing unless the federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition - Out of 28 payments to subrecipients that were tested, 12 were made after the 30-calendar-day requirement, 10 and 2 from the R&D Cluster and ALN 17.268, respectively. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related solely to timeliness of payments. Context - In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 39 - 242 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - The University does have formal general accounts payable and cash disbursement processes in place; however, there are no specific controls in place to ensure that subrecipients are paid within the 30-day requirement. Although all of the payments were ultimately made, the lack of controls resulted in several late payments. Recommendation - The University should implement a control to ensure that payments are made within the required time frame. Views of Responsible Officials and Corrective Action Plan - Accounts payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expenditure. For federal award expenditures, accounts payable will manually change the payment terms to 30 calendar days or less to ensure compliance. Periodically, accounts payable will review open federal award payables to verify payment terms have been properly set for the 30-day compliance requirement. The Controller’s and Accounts Payable offices will also explore creating a more efficient long-term solution, whereby the 30-day terms could be automatically set during the purchase order creation process. This would eliminate any manual updates to the payment terms by accounts payable personnel. The Sponsored Research Services Accounting Office will send reminders to all college business officers and principal investigators (PIs) to highlight the need for prompt review and approval of federal award invoices. This language will be incorporated into the SRS Best Grant Practices training classes, as well as the University’s fundamentals of sponsored administration training courses.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 20.232, U.S. Department of Transportation, Commercial Driver's License Program Implementation Grant - 93.350, U.S. Department of Health and Human Services, National Center for Advancing Translational Sciences - 93.279, U.S. Department of Health and Human Services, Drug Abuse and Addiction Research Programs - 93.853, U.S. Department of Health and Human Services, Extramural Research Programs in the Neurosciences and Neurological Disorders - 93.866, U.S. Department of Health and Human Services, Aging Research Non-Research and Development Cluster: - 17.268, Department of Labor, H-1B Job Training Federal Award Identification Number and Year - Research and Development Cluster: - 20.323 - FM-CDL-0435-20-01-00 - 93.350 - UTR001425B - 93.279 - OSU SPC-1000006389 UM1DA; UDA013732E - 93.853 - SUBK00007313 SLEEP SMART; UNS110772A - 93.866 - RAG072592A 17.268: HG-33044-19-60-A-39, 2019 Pass-through Entity - 93.279 - The Ohio State University; 93.853 - University of Michigan Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a payment within 30 calendar days after receipt of the billing unless the federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition - Out of 28 payments to subrecipients that were tested, 12 were made after the 30-calendar-day requirement, 10 and 2 from the R&D Cluster and ALN 17.268, respectively. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related solely to timeliness of payments. Context - In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 39 - 242 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - The University does have formal general accounts payable and cash disbursement processes in place; however, there are no specific controls in place to ensure that subrecipients are paid within the 30-day requirement. Although all of the payments were ultimately made, the lack of controls resulted in several late payments. Recommendation - The University should implement a control to ensure that payments are made within the required time frame. Views of Responsible Officials and Corrective Action Plan - Accounts payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expenditure. For federal award expenditures, accounts payable will manually change the payment terms to 30 calendar days or less to ensure compliance. Periodically, accounts payable will review open federal award payables to verify payment terms have been properly set for the 30-day compliance requirement. The Controller’s and Accounts Payable offices will also explore creating a more efficient long-term solution, whereby the 30-day terms could be automatically set during the purchase order creation process. This would eliminate any manual updates to the payment terms by accounts payable personnel. The Sponsored Research Services Accounting Office will send reminders to all college business officers and principal investigators (PIs) to highlight the need for prompt review and approval of federal award invoices. This language will be incorporated into the SRS Best Grant Practices training classes, as well as the University’s fundamentals of sponsored administration training courses.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 20.232, U.S. Department of Transportation, Commercial Driver's License Program Implementation Grant - 93.350, U.S. Department of Health and Human Services, National Center for Advancing Translational Sciences - 93.279, U.S. Department of Health and Human Services, Drug Abuse and Addiction Research Programs - 93.853, U.S. Department of Health and Human Services, Extramural Research Programs in the Neurosciences and Neurological Disorders - 93.866, U.S. Department of Health and Human Services, Aging Research Non-Research and Development Cluster: - 17.268, Department of Labor, H-1B Job Training Federal Award Identification Number and Year - Research and Development Cluster: - 20.323 - FM-CDL-0435-20-01-00 - 93.350 - UTR001425B - 93.279 - OSU SPC-1000006389 UM1DA; UDA013732E - 93.853 - SUBK00007313 SLEEP SMART; UNS110772A - 93.866 - RAG072592A 17.268: HG-33044-19-60-A-39, 2019 Pass-through Entity - 93.279 - The Ohio State University; 93.853 - University of Michigan Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a payment within 30 calendar days after receipt of the billing unless the federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition - Out of 28 payments to subrecipients that were tested, 12 were made after the 30-calendar-day requirement, 10 and 2 from the R&D Cluster and ALN 17.268, respectively. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related solely to timeliness of payments. Context - In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 39 - 242 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - The University does have formal general accounts payable and cash disbursement processes in place; however, there are no specific controls in place to ensure that subrecipients are paid within the 30-day requirement. Although all of the payments were ultimately made, the lack of controls resulted in several late payments. Recommendation - The University should implement a control to ensure that payments are made within the required time frame. Views of Responsible Officials and Corrective Action Plan - Accounts payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expenditure. For federal award expenditures, accounts payable will manually change the payment terms to 30 calendar days or less to ensure compliance. Periodically, accounts payable will review open federal award payables to verify payment terms have been properly set for the 30-day compliance requirement. The Controller’s and Accounts Payable offices will also explore creating a more efficient long-term solution, whereby the 30-day terms could be automatically set during the purchase order creation process. This would eliminate any manual updates to the payment terms by accounts payable personnel. The Sponsored Research Services Accounting Office will send reminders to all college business officers and principal investigators (PIs) to highlight the need for prompt review and approval of federal award invoices. This language will be incorporated into the SRS Best Grant Practices training classes, as well as the University’s fundamentals of sponsored administration training courses.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 20.232, U.S. Department of Transportation, Commercial Driver's License Program Implementation Grant - 93.350, U.S. Department of Health and Human Services, National Center for Advancing Translational Sciences - 93.279, U.S. Department of Health and Human Services, Drug Abuse and Addiction Research Programs - 93.853, U.S. Department of Health and Human Services, Extramural Research Programs in the Neurosciences and Neurological Disorders - 93.866, U.S. Department of Health and Human Services, Aging Research Non-Research and Development Cluster: - 17.268, Department of Labor, H-1B Job Training Federal Award Identification Number and Year - Research and Development Cluster: - 20.323 - FM-CDL-0435-20-01-00 - 93.350 - UTR001425B - 93.279 - OSU SPC-1000006389 UM1DA; UDA013732E - 93.853 - SUBK00007313 SLEEP SMART; UNS110772A - 93.866 - RAG072592A 17.268: HG-33044-19-60-A-39, 2019 Pass-through Entity - 93.279 - The Ohio State University; 93.853 - University of Michigan Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a payment within 30 calendar days after receipt of the billing unless the federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition - Out of 28 payments to subrecipients that were tested, 12 were made after the 30-calendar-day requirement, 10 and 2 from the R&D Cluster and ALN 17.268, respectively. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related solely to timeliness of payments. Context - In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 39 - 242 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - The University does have formal general accounts payable and cash disbursement processes in place; however, there are no specific controls in place to ensure that subrecipients are paid within the 30-day requirement. Although all of the payments were ultimately made, the lack of controls resulted in several late payments. Recommendation - The University should implement a control to ensure that payments are made within the required time frame. Views of Responsible Officials and Corrective Action Plan - Accounts payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expenditure. For federal award expenditures, accounts payable will manually change the payment terms to 30 calendar days or less to ensure compliance. Periodically, accounts payable will review open federal award payables to verify payment terms have been properly set for the 30-day compliance requirement. The Controller’s and Accounts Payable offices will also explore creating a more efficient long-term solution, whereby the 30-day terms could be automatically set during the purchase order creation process. This would eliminate any manual updates to the payment terms by accounts payable personnel. The Sponsored Research Services Accounting Office will send reminders to all college business officers and principal investigators (PIs) to highlight the need for prompt review and approval of federal award invoices. This language will be incorporated into the SRS Best Grant Practices training classes, as well as the University’s fundamentals of sponsored administration training courses.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 20.232, U.S. Department of Transportation, Commercial Driver's License Program Implementation Grant - 93.350, U.S. Department of Health and Human Services, National Center for Advancing Translational Sciences - 93.279, U.S. Department of Health and Human Services, Drug Abuse and Addiction Research Programs - 93.853, U.S. Department of Health and Human Services, Extramural Research Programs in the Neurosciences and Neurological Disorders - 93.866, U.S. Department of Health and Human Services, Aging Research Non-Research and Development Cluster: - 17.268, Department of Labor, H-1B Job Training Federal Award Identification Number and Year - Research and Development Cluster: - 20.323 - FM-CDL-0435-20-01-00 - 93.350 - UTR001425B - 93.279 - OSU SPC-1000006389 UM1DA; UDA013732E - 93.853 - SUBK00007313 SLEEP SMART; UNS110772A - 93.866 - RAG072592A 17.268: HG-33044-19-60-A-39, 2019 Pass-through Entity - 93.279 - The Ohio State University; 93.853 - University of Michigan Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a payment within 30 calendar days after receipt of the billing unless the federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition - Out of 28 payments to subrecipients that were tested, 12 were made after the 30-calendar-day requirement, 10 and 2 from the R&D Cluster and ALN 17.268, respectively. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related solely to timeliness of payments. Context - In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 39 - 242 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - The University does have formal general accounts payable and cash disbursement processes in place; however, there are no specific controls in place to ensure that subrecipients are paid within the 30-day requirement. Although all of the payments were ultimately made, the lack of controls resulted in several late payments. Recommendation - The University should implement a control to ensure that payments are made within the required time frame. Views of Responsible Officials and Corrective Action Plan - Accounts payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expenditure. For federal award expenditures, accounts payable will manually change the payment terms to 30 calendar days or less to ensure compliance. Periodically, accounts payable will review open federal award payables to verify payment terms have been properly set for the 30-day compliance requirement. The Controller’s and Accounts Payable offices will also explore creating a more efficient long-term solution, whereby the 30-day terms could be automatically set during the purchase order creation process. This would eliminate any manual updates to the payment terms by accounts payable personnel. The Sponsored Research Services Accounting Office will send reminders to all college business officers and principal investigators (PIs) to highlight the need for prompt review and approval of federal award invoices. This language will be incorporated into the SRS Best Grant Practices training classes, as well as the University’s fundamentals of sponsored administration training courses.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 20.232, U.S. Department of Transportation, Commercial Driver's License Program Implementation Grant - 93.350, U.S. Department of Health and Human Services, National Center for Advancing Translational Sciences - 93.279, U.S. Department of Health and Human Services, Drug Abuse and Addiction Research Programs - 93.853, U.S. Department of Health and Human Services, Extramural Research Programs in the Neurosciences and Neurological Disorders - 93.866, U.S. Department of Health and Human Services, Aging Research Non-Research and Development Cluster: - 17.268, Department of Labor, H-1B Job Training Federal Award Identification Number and Year - Research and Development Cluster: - 20.323 - FM-CDL-0435-20-01-00 - 93.350 - UTR001425B - 93.279 - OSU SPC-1000006389 UM1DA; UDA013732E - 93.853 - SUBK00007313 SLEEP SMART; UNS110772A - 93.866 - RAG072592A 17.268: HG-33044-19-60-A-39, 2019 Pass-through Entity - 93.279 - The Ohio State University; 93.853 - University of Michigan Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a payment within 30 calendar days after receipt of the billing unless the federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition - Out of 28 payments to subrecipients that were tested, 12 were made after the 30-calendar-day requirement, 10 and 2 from the R&D Cluster and ALN 17.268, respectively. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related solely to timeliness of payments. Context - In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 39 - 242 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - The University does have formal general accounts payable and cash disbursement processes in place; however, there are no specific controls in place to ensure that subrecipients are paid within the 30-day requirement. Although all of the payments were ultimately made, the lack of controls resulted in several late payments. Recommendation - The University should implement a control to ensure that payments are made within the required time frame. Views of Responsible Officials and Corrective Action Plan - Accounts payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expenditure. For federal award expenditures, accounts payable will manually change the payment terms to 30 calendar days or less to ensure compliance. Periodically, accounts payable will review open federal award payables to verify payment terms have been properly set for the 30-day compliance requirement. The Controller’s and Accounts Payable offices will also explore creating a more efficient long-term solution, whereby the 30-day terms could be automatically set during the purchase order creation process. This would eliminate any manual updates to the payment terms by accounts payable personnel. The Sponsored Research Services Accounting Office will send reminders to all college business officers and principal investigators (PIs) to highlight the need for prompt review and approval of federal award invoices. This language will be incorporated into the SRS Best Grant Practices training classes, as well as the University’s fundamentals of sponsored administration training courses.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.