Assistance Listings number and name: 84.425F COVID-19 Education Stabilization Fund—Institutional Portion Award number and year: P425F200677, May 4, 2020 through June 30, 2023 Federal agency: U.S. Department of Education Compliance requirements: Allowable costs/cost principles and cash management Questioned costs: $10,217,259 Condition—Contrary to federal guidance and regulations and Northern Arizona University’s (University) federal indirect cost agreement, for fiscal years 2020 through 2022, the University incorrectly calculated its federal indirect costs by applying its indirect cost rate to capital expenditures and lost revenues and requested and received reimbursement for direct program expenditures it did not incur. Effect—The University overcharged $10,217,259 of unallowed costs to its HEERF program’s institutional portion for fiscal years 2020 through 2022, resulting in less monies available to spend on allowable program costs for addressing institutional needs, such as defraying costs associated with COVID-19 (including lost revenue and payroll). These unallowed costs included $2,473,496 in indirect costs related to capital expenditures, $7,449,036 in indirect costs related to lost revenues, and $294,727 for direct expenditures it did not incur and that comprised 8.5 percent of the University’s portion of the program’s total federal award expenditures for fiscal years 2020 through 2022. The University returned these unallowed costs to the U.S. Department of Education (ED) on August 18, 2023. Cause—The University did not properly train the individual administering the program or require secondary reviews of indirect-cost calculations and reimbursement requests. Specifically, despite the requirements in its federal indirect cost rate agreement and ED’s guidance, the University’s administration reported that the individual performing the indirect-cost calculation was not properly trained on calculating indirect costs and therefore, did not realize that the indirect cost rate should not have been applied to capital expenditures and lost revenues. Also, the University did not follow written policy and have a second employee who was knowledgeable about the program review and approve the indirect-cost calculation for accuracy. Similarly, a second employee did not review reimbursement requests or reconcile program expenditures to its financial accounting system, and the University’s policy lacked such requirements. Criteria—Federal guidance and regulations require the University to follow its federal indirect cost agreement to apply and calculate indirect costs allocated to federal programs at the specific percentages for specific costs that comprise the program’s base expenditures.1 The University’s federal indirect cost agreement and ED’s guidance does not allow the University to apply an indirect cost rate to its capital expenditures and estimated amount of lost revenue.2 In addition, University policy requires an independent review and approval of all transactions recorded in its accounting system, including indirect-cost calculations, to ensure that they are appropriate, accurate, and comply with applicable laws and regulations (Northern Arizona University Comptroller Manual, CMP 603). Further, federal regulation requires the University to use the reimbursement method to administer the program, whereby the Office is reimbursed with federal program monies only after it spends its own monies for authorized program purposes and requests reimbursement from the federal grantor (2 CFR §200.305[b][3]). Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The University should: 1. Correctly calculate federal indirect costs by: a. Training employees responsible for calculating federal program indirect costs to properly apply the award’s indirect cost rate to only allowable program expenditures as outlined in the indirect cost agreement and grant awards. b. Following written policy for reviewing federal program transactions, including ensuring indirect-cost calculations are properly reviewed and approved. 2. Ensure only federal program costs incurred are requested for reimbursement by improving its written policy to require a second employee to reconcile program expenditures recorded on its financial accounting system to the reimbursement request before approving the request to be submitted to the federal grantor. The University’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 U.S. Department of Education. (2021). Higher Education Emergency Relief Fund III—Frequently Asked Questions, Question 43. Retrieved 5/19/2023 from https://www2.ed.gov/about/offices/list/ope/arpfaq.pdf. U.S. Office of Management and Budget. (2021). Appendix III to 2 CFR Part 200—Indirect (F&A) Costs Identification and Assignment, and Rate Determinations for Institutions of Higher Education. Retrieved 5/19/2023 from https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/appendix-Appendix%20III%20to%20Part%20200. 2 Executive Office of the President, Office of Management and Budget. 2 CFR Part 200, Appendix XI Compliance Supplement, page 4-84.425-ESF-38. (2002). Retrieved 5/19/2023 from https://www.whitehouse.gov/wp-content/uploads/2022/05/2022-Compliance-Supplement_PDF_Rev_05.11.22.pdf.
Assistance Listings number and name: 84.425F COVID-19 Education Stabilization Fund—Institutional Portion Award number and year: P425F200677, May 4, 2020 through June 30, 2023 Federal agency: U.S. Department of Education Compliance requirements: Allowable costs/cost principles and cash management Questioned costs: $10,217,259 Condition—Contrary to federal guidance and regulations and Northern Arizona University’s (University) federal indirect cost agreement, for fiscal years 2020 through 2022, the University incorrectly calculated its federal indirect costs by applying its indirect cost rate to capital expenditures and lost revenues and requested and received reimbursement for direct program expenditures it did not incur. Effect—The University overcharged $10,217,259 of unallowed costs to its HEERF program’s institutional portion for fiscal years 2020 through 2022, resulting in less monies available to spend on allowable program costs for addressing institutional needs, such as defraying costs associated with COVID-19 (including lost revenue and payroll). These unallowed costs included $2,473,496 in indirect costs related to capital expenditures, $7,449,036 in indirect costs related to lost revenues, and $294,727 for direct expenditures it did not incur and that comprised 8.5 percent of the University’s portion of the program’s total federal award expenditures for fiscal years 2020 through 2022. The University returned these unallowed costs to the U.S. Department of Education (ED) on August 18, 2023. Cause—The University did not properly train the individual administering the program or require secondary reviews of indirect-cost calculations and reimbursement requests. Specifically, despite the requirements in its federal indirect cost rate agreement and ED’s guidance, the University’s administration reported that the individual performing the indirect-cost calculation was not properly trained on calculating indirect costs and therefore, did not realize that the indirect cost rate should not have been applied to capital expenditures and lost revenues. Also, the University did not follow written policy and have a second employee who was knowledgeable about the program review and approve the indirect-cost calculation for accuracy. Similarly, a second employee did not review reimbursement requests or reconcile program expenditures to its financial accounting system, and the University’s policy lacked such requirements. Criteria—Federal guidance and regulations require the University to follow its federal indirect cost agreement to apply and calculate indirect costs allocated to federal programs at the specific percentages for specific costs that comprise the program’s base expenditures.1 The University’s federal indirect cost agreement and ED’s guidance does not allow the University to apply an indirect cost rate to its capital expenditures and estimated amount of lost revenue.2 In addition, University policy requires an independent review and approval of all transactions recorded in its accounting system, including indirect-cost calculations, to ensure that they are appropriate, accurate, and comply with applicable laws and regulations (Northern Arizona University Comptroller Manual, CMP 603). Further, federal regulation requires the University to use the reimbursement method to administer the program, whereby the Office is reimbursed with federal program monies only after it spends its own monies for authorized program purposes and requests reimbursement from the federal grantor (2 CFR §200.305[b][3]). Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The University should: 1. Correctly calculate federal indirect costs by: a. Training employees responsible for calculating federal program indirect costs to properly apply the award’s indirect cost rate to only allowable program expenditures as outlined in the indirect cost agreement and grant awards. b. Following written policy for reviewing federal program transactions, including ensuring indirect-cost calculations are properly reviewed and approved. 2. Ensure only federal program costs incurred are requested for reimbursement by improving its written policy to require a second employee to reconcile program expenditures recorded on its financial accounting system to the reimbursement request before approving the request to be submitted to the federal grantor. The University’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 U.S. Department of Education. (2021). Higher Education Emergency Relief Fund III—Frequently Asked Questions, Question 43. Retrieved 5/19/2023 from https://www2.ed.gov/about/offices/list/ope/arpfaq.pdf. U.S. Office of Management and Budget. (2021). Appendix III to 2 CFR Part 200—Indirect (F&A) Costs Identification and Assignment, and Rate Determinations for Institutions of Higher Education. Retrieved 5/19/2023 from https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/appendix-Appendix%20III%20to%20Part%20200. 2 Executive Office of the President, Office of Management and Budget. 2 CFR Part 200, Appendix XI Compliance Supplement, page 4-84.425-ESF-38. (2002). Retrieved 5/19/2023 from https://www.whitehouse.gov/wp-content/uploads/2022/05/2022-Compliance-Supplement_PDF_Rev_05.11.22.pdf.
Assistance Listings number and name: 84.425F COVID-19 Education Stabilization Fund—Institutional Portion Award number and year: P425F200677, May 4, 2020 through June 30, 2023 Federal agency: U.S. Department of Education Compliance requirements: Allowable costs/cost principles and cash management Questioned costs: $10,217,259 Condition—Contrary to federal guidance and regulations and Northern Arizona University’s (University) federal indirect cost agreement, for fiscal years 2020 through 2022, the University incorrectly calculated its federal indirect costs by applying its indirect cost rate to capital expenditures and lost revenues and requested and received reimbursement for direct program expenditures it did not incur. Effect—The University overcharged $10,217,259 of unallowed costs to its HEERF program’s institutional portion for fiscal years 2020 through 2022, resulting in less monies available to spend on allowable program costs for addressing institutional needs, such as defraying costs associated with COVID-19 (including lost revenue and payroll). These unallowed costs included $2,473,496 in indirect costs related to capital expenditures, $7,449,036 in indirect costs related to lost revenues, and $294,727 for direct expenditures it did not incur and that comprised 8.5 percent of the University’s portion of the program’s total federal award expenditures for fiscal years 2020 through 2022. The University returned these unallowed costs to the U.S. Department of Education (ED) on August 18, 2023. Cause—The University did not properly train the individual administering the program or require secondary reviews of indirect-cost calculations and reimbursement requests. Specifically, despite the requirements in its federal indirect cost rate agreement and ED’s guidance, the University’s administration reported that the individual performing the indirect-cost calculation was not properly trained on calculating indirect costs and therefore, did not realize that the indirect cost rate should not have been applied to capital expenditures and lost revenues. Also, the University did not follow written policy and have a second employee who was knowledgeable about the program review and approve the indirect-cost calculation for accuracy. Similarly, a second employee did not review reimbursement requests or reconcile program expenditures to its financial accounting system, and the University’s policy lacked such requirements. Criteria—Federal guidance and regulations require the University to follow its federal indirect cost agreement to apply and calculate indirect costs allocated to federal programs at the specific percentages for specific costs that comprise the program’s base expenditures.1 The University’s federal indirect cost agreement and ED’s guidance does not allow the University to apply an indirect cost rate to its capital expenditures and estimated amount of lost revenue.2 In addition, University policy requires an independent review and approval of all transactions recorded in its accounting system, including indirect-cost calculations, to ensure that they are appropriate, accurate, and comply with applicable laws and regulations (Northern Arizona University Comptroller Manual, CMP 603). Further, federal regulation requires the University to use the reimbursement method to administer the program, whereby the Office is reimbursed with federal program monies only after it spends its own monies for authorized program purposes and requests reimbursement from the federal grantor (2 CFR §200.305[b][3]). Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The University should: 1. Correctly calculate federal indirect costs by: a. Training employees responsible for calculating federal program indirect costs to properly apply the award’s indirect cost rate to only allowable program expenditures as outlined in the indirect cost agreement and grant awards. b. Following written policy for reviewing federal program transactions, including ensuring indirect-cost calculations are properly reviewed and approved. 2. Ensure only federal program costs incurred are requested for reimbursement by improving its written policy to require a second employee to reconcile program expenditures recorded on its financial accounting system to the reimbursement request before approving the request to be submitted to the federal grantor. The University’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 U.S. Department of Education. (2021). Higher Education Emergency Relief Fund III—Frequently Asked Questions, Question 43. Retrieved 5/19/2023 from https://www2.ed.gov/about/offices/list/ope/arpfaq.pdf. U.S. Office of Management and Budget. (2021). Appendix III to 2 CFR Part 200—Indirect (F&A) Costs Identification and Assignment, and Rate Determinations for Institutions of Higher Education. Retrieved 5/19/2023 from https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/appendix-Appendix%20III%20to%20Part%20200. 2 Executive Office of the President, Office of Management and Budget. 2 CFR Part 200, Appendix XI Compliance Supplement, page 4-84.425-ESF-38. (2002). Retrieved 5/19/2023 from https://www.whitehouse.gov/wp-content/uploads/2022/05/2022-Compliance-Supplement_PDF_Rev_05.11.22.pdf.
Description: Cash Management for Subrecipient Expenditures Repeat Finding: No Type of Finding: Material weakness in internal controls and material non-compliance with the cash management compliance requirement Questioned Costs: None Major Program: AL # 64.033, VA Supportive Services for Veteran Families Program, #20-OR-430 and #20-OR-430-C3. Condition: During the year ended June 30, 2022, the Organization regularly drew down cash from the Payment Management System (PMS) for subrecipient expenditures but did not remit the related payments to the subrecipients in a timely manner. Review of supporting documentation submitted by subrecipients for their expenditures did not occur prior to drawing down the cash from PMS for the related expenditures. Criteria: Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity (2 CFR section 200.305(b)). Cause: The Organization did not ensure its service provider was properly managing subrecipient cash requests and disbursements throughout the year and was not consistently reviewing subrecipient expenditure requests in a timely manner. Effect: As a result of the matter identified in the condition paragraph, a material weakness in the Organization’s internal controls over compliance and a material non-compliance exist for the cash management compliance requirement. Recommendation: We recommend the Organization implements procedures to ensure it is properly managing the timing of subrecipient cash requests and disbursements to comply with the cash management requirement. View of responsible officials: Management agrees with the assessment and has committed to a corrective action plan.
State Agency: Illinois Department of Revenue (IDOR) Federal Agency: U.S. Department of Treasury (Treasury) Program Name: COVID-19 – Homeowner Assistance Fund ALN and Program Expenditures: 21.026 ($209,795,189) Award Numbers: Various – See schedule of award numbers Federal Award Year: Various – See schedule of award numbers Questioned Costs: None Compliance Requirement: Cash Management Finding 2022-003: Failure to Monitor Subrecipient Cash Draws Type of Finding: Adverse opinion and material weaknessCondition Found: IDOR passed through most of the advance drawn funds to its subrecipient while reporting no activity had occurred for the COVID–19 – Homeowner Assistance Fund (HAF) program in the special report prepared during fiscal year 2022. The State designated IDOR as the State agency responsible for fiscal activities of the COVID-19 – HAF program. IDOR passed funding through to the Illinois Housing Development Authority (IHDA) (a component unit of the State) who works directly with program beneficiaries (eligible homeowners or subrecipients). During our audit procedures, we noted the State received $211,309,688 of COVID-19 – HAF program funding from the U.S. Treasury in January 2022. At the time of the January 2022 cash receipt, we noted IDOR had passed through $32,886,765 to IHDA. During our review of subrecipient payments (totaling $209,795,189) made to IHDA during the year ended June 30, 2022, we noted IHDA had only reported expenditures of $6,901,019 during the year ended June 30, 2022. Accordingly, IDOR had provided HAF program advances totaling $202,894,170 during the year ended June 30, 2022. IDOR did not have procedures in place to monitor whether IHDA had incurred or would be incurring program expenditures to minimize federal cash on hand. Additionally, the State prepared and submitted a one-time special report (Interim Report 1505-0269) that covered the reporting period beginning on the date of the COVID-19 – HAF program award (May 3, 2021) through January 31, 2022. The key line items in the special report included the following: • Number of unique Homeowners that received HAF assistance and subset(s) that are classified as Socially Disadvantaged and 100 percent Area Median Income (AMI) or less • Homeowners that received HAF assistance disaggregated by Program Design Element • Amount of assistance provided to Homeowners disaggregated by Program Design Element During our testing of the COVID-19 – HAF program special report, we noted the State did not report activity data for any of the key line items. Total subrecipient expenditures for the HAF program administered by the State were $209,795,189 during the year end June 30, 2022.Criteria or Requirement: Pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized as required by the applicable cash management requirements in the federal award to the recipient (2 CFR section 200.305(b)(1)). In addition, 2 CFR 200.303 requires non-federal entities receiving Federal awards to establish and maintain internal control designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include establishing procedures to minimize the time elapsing between the transfer of funds to subrecipients and the subrecipient’s actual cash outlay for program costs. Cause: The State’s relationship with IHDA is a multi-agency initiative. IDOR’s role has historically been statutorily limited to funding agent. This role does not include expenditure monitoring or reporting responsibilities. There was confusion in fiscal year 2022 regarding which state agency would perform these tasks for the COVID grant money awarded to IHDA. Possible Asserted Effect: Failure to monitor whether subrecipients minimize the time between the receipt of federal funds and expenditure for program purposes may result in advance funding in excess of immediate cash needs. Additionally, failure to properly report program activities in required special reports inhibits the U.S. Treasury from properly monitoring program activities and progress. Repeat Finding: A similar finding was not reported in a prior year audit. (Finding Code No. 2022-003) Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend IDOR implement procedures to monitor subrecipients to ensure funds are requested only for expenditures which have been incurred or will be incurred within a reasonable time period to minimize federal cash on hand. Additionally, the State should implement procedures to ensure the COVID-19 – HAF program special report completely and accurately describes required program activities. Views of IDOR Officials: The IHDA Act was updated to allow IDOR to disburse COVID money. However, the language for the tasks to be performed by the funding agent was left unchanged. This ambiguity along with the reporting IHDA does to other agencies contributed to confusion regarding which agency was responsible for the grant expenditure monitoring and reporting. IDOR pursued legislative clarification. This resulted in the decision to transition the funding agent role to DHS.
Condition: The Center?s written policies and procedures related to financial management do not meet the requirements of 2 CFR 200, Subpart D and Subpart E. Criteria: According to 2 CFR Section 200.302.b and 2 CFR Section 200.305 of the Uniform Guidance, the Center is required to have a written financial management policy. Cause: The Center was unaware of requirements regarding policies and procedures outlined in the Uniform Guidance. Effect: Written policies necessary for non-Federal entities receiving federal funds were not in place. Repeat Finding: No Questioned Costs: None reported Recommendation: We recommend that the Center update their written policies and procedures that meet the requirements of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Views of Responsible Officials and Planned Corrective Action: We concur with the auditor?s finding and will update the Center?s written policies and procedures for the Uniform Guidance requirements.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.