Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient. Cause: Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval. Effect or Potential Effect: The University was not in compliance with the cash management requirements of a pass-through entity. Questioned Costs: None. Context: For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner. Identification as a Repeat Finding: This is a repeat of prior year finding 2023-015. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.