Federal Agency: U. S. Department of Health and Human Services Federal Program Name: Research and Development Cluster Assistance Listing Number: 93.323, 93.847 Federal Award Identification Number and Year: G231006 (23/24), R01DK108054 (23/24) Pass-Through Agency: WV Department of Health and Human Resources Pass-Through Number(s): G231006 Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal awards period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). A period of performance may contain one or more budget periods. Condition: In a sample of transactions that were in the expense detail supporting the total federal expenditures on the Schedule of Expenditures of Federal Awards (SEFA), transactions were identified as being incurred after the end date of the period of availability. Questioned costs: $3,320 Context: In a sample size of twenty-eight expenditure transactions, five were incurred after the end date of the period of availability. Cause: Four of the exceptions were the result of the department administering the grant not submitting a revised internal form to update the funding source. These transactions were not included on the final invoice to the awarding agency but were included in the SEFA. One of the exceptions was the result of clerical entry error. • • Effect: Amounts are included on the SEFA for the fiscal period ended June 30, 2024, that were incurred after the end date of the period of performance. Repeat finding: No. Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Views of responsible officials: There is no disagreement with the audit finding.
Finding number: 2024-011 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Student Support and Academic Enrichment Program ALN #: 84.424 Award number: 0309-000548-2024-0035 Award year: September 12, 2023 to September 30, 2025 Finding: Internal Control and Compliance over Period of Performance Prior Year Finding: No Type of Finding: Material Weakness and Material Noncompliance Criteria Period of Performance A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308, 200.309, and 200.403(h). A period of performance may contain one or more budget periods. LEAs and SEAs must obligate funds during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. This maximum period includes a 15-month period of initial availability plus a 12-month period for carryover. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of period of performance associated with those expenditures charged to grant awards which began during fiscal year 2024 and cost transfers, we noted noncompliance for 2 expenditures out of a sample of 4. Per review of the underlying vendor invoices, the service period for these expenditures started prior to the award start date of September 12, 2023.Cause This appears to be due to an insufficient review of invoices to ensure the underlying services performed by vendors are within the grant awards outlined grant period. Effect Insufficient review of vendor invoices increases the risk of costs being charged to a grant award outside its approved budget period. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: $1,250,864 Recommendation We recommend that the Boston Public Schools (BPS) re-enforce its policies and procedures to ensure their review of expenditures charged to the award also includes a detailed review of the underlying vendor service period. View of Responsible Officials from the Auditee BPS will take a multi-step approach to ensuring accuracy of spending to the grant award period: 1. Reinforce our existing practice of ensuring that period of service is reflected on Purchase Orders, which it was for the PO’s in question. 2. Working with major suppliers to ensure they understand the grant funded nature of their program and the eligible dates of service, which are outlined on the Purchase Order 3. Review / Update training for our Accounts Payable team on ensuring that the period of service on an invoice matches the period of service on the Purchase Order 4. Review / Update training for our State & Federal Grants, Programs, and Compliance teams to ensure that expenses are reviewed before the end of the grant period to ensure compliance with federal regulations.
FINDING 2024-005 Subject: Special Education Cluster (IDEA) - Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, 22619-047-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Period of Performance Audit Findings: Material Weakness, Other Matters Condition and Context During the audit period, the School Corporation was a member of the Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For Special Education Cluster awards, funds must be obligated during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. When testing transactions which occurred in the liquidation period for the 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, and 22619-047-ARP grant awards, two exceptions were identified in the initial sample of five transactions. When expanding the sample, a third exception was noted, and it was concluded that it would not be appropriate to examine the remaining 14 transactions. For the above listed awards, costs must be obligated by September 30, 2023. For the three identified exceptions, an initial purchase order was made in September, but the ultimate transaction was paid to a separate vendor than the original purchase order, and this obligation was incurred in November 2023. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 22 NORTH NEWTON SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.403(h) states: "Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3)." 34 CFR 76.707 states in part: ". . . If the obligation is for- . . . (d) Performance of work other than personal services. . . . The obligation is made- On the date on which the State or subgrantee makes a binding written commitment to acquire the property. . . ." 2 CFR 200.1 states in part: ". . . Period of Performance means the total estimated time interval between the start of an initial Federal award and the planned end date . . ." 36 CFR 76.709(a) states: "If a State or a subgrantee does not obligate all of its grant or subgrant funds by the end of the fiscal year for which Congress appropriated the funds, it may obligate the remaining funds during a carryover period of one additional fiscal year." Cause Management had established an initial obligation date that occurred in September of the second fiscal year but modified the final vendor for payment. The new obligation occurred after the period in which the School Corporation was allowed to incur the expense. Effect If funds are not obligated by the end of the specified date, the grantor agency is not obligated to reimburse the School Corporation for costs incurred. This may indicate that the funding that was reimbursed, which incurred outside of the period of performance, will need to be repaid to the grantor agency, and the School Corporation will then need to support the costs with nonfederal funding. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that no costs are incurred after the September 30 deadline and to ensure compliance with the grant agreement and the Period of Performance compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: Special Education Cluster (IDEA) - Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, 22619-047-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Period of Performance Audit Findings: Material Weakness, Other Matters Condition and Context During the audit period, the School Corporation was a member of the Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For Special Education Cluster awards, funds must be obligated during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. When testing transactions which occurred in the liquidation period for the 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, and 22619-047-ARP grant awards, two exceptions were identified in the initial sample of five transactions. When expanding the sample, a third exception was noted, and it was concluded that it would not be appropriate to examine the remaining 14 transactions. For the above listed awards, costs must be obligated by September 30, 2023. For the three identified exceptions, an initial purchase order was made in September, but the ultimate transaction was paid to a separate vendor than the original purchase order, and this obligation was incurred in November 2023. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 22 NORTH NEWTON SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.403(h) states: "Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3)." 34 CFR 76.707 states in part: ". . . If the obligation is for- . . . (d) Performance of work other than personal services. . . . The obligation is made- On the date on which the State or subgrantee makes a binding written commitment to acquire the property. . . ." 2 CFR 200.1 states in part: ". . . Period of Performance means the total estimated time interval between the start of an initial Federal award and the planned end date . . ." 36 CFR 76.709(a) states: "If a State or a subgrantee does not obligate all of its grant or subgrant funds by the end of the fiscal year for which Congress appropriated the funds, it may obligate the remaining funds during a carryover period of one additional fiscal year." Cause Management had established an initial obligation date that occurred in September of the second fiscal year but modified the final vendor for payment. The new obligation occurred after the period in which the School Corporation was allowed to incur the expense. Effect If funds are not obligated by the end of the specified date, the grantor agency is not obligated to reimburse the School Corporation for costs incurred. This may indicate that the funding that was reimbursed, which incurred outside of the period of performance, will need to be repaid to the grantor agency, and the School Corporation will then need to support the costs with nonfederal funding. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that no costs are incurred after the September 30 deadline and to ensure compliance with the grant agreement and the Period of Performance compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: Special Education Cluster (IDEA) - Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, 22619-047-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Period of Performance Audit Findings: Material Weakness, Other Matters Condition and Context During the audit period, the School Corporation was a member of the Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For Special Education Cluster awards, funds must be obligated during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. When testing transactions which occurred in the liquidation period for the 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, and 22619-047-ARP grant awards, two exceptions were identified in the initial sample of five transactions. When expanding the sample, a third exception was noted, and it was concluded that it would not be appropriate to examine the remaining 14 transactions. For the above listed awards, costs must be obligated by September 30, 2023. For the three identified exceptions, an initial purchase order was made in September, but the ultimate transaction was paid to a separate vendor than the original purchase order, and this obligation was incurred in November 2023. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 22 NORTH NEWTON SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.403(h) states: "Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3)." 34 CFR 76.707 states in part: ". . . If the obligation is for- . . . (d) Performance of work other than personal services. . . . The obligation is made- On the date on which the State or subgrantee makes a binding written commitment to acquire the property. . . ." 2 CFR 200.1 states in part: ". . . Period of Performance means the total estimated time interval between the start of an initial Federal award and the planned end date . . ." 36 CFR 76.709(a) states: "If a State or a subgrantee does not obligate all of its grant or subgrant funds by the end of the fiscal year for which Congress appropriated the funds, it may obligate the remaining funds during a carryover period of one additional fiscal year." Cause Management had established an initial obligation date that occurred in September of the second fiscal year but modified the final vendor for payment. The new obligation occurred after the period in which the School Corporation was allowed to incur the expense. Effect If funds are not obligated by the end of the specified date, the grantor agency is not obligated to reimburse the School Corporation for costs incurred. This may indicate that the funding that was reimbursed, which incurred outside of the period of performance, will need to be repaid to the grantor agency, and the School Corporation will then need to support the costs with nonfederal funding. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that no costs are incurred after the September 30 deadline and to ensure compliance with the grant agreement and the Period of Performance compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: Special Education Cluster (IDEA) - Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, 22619-047-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Period of Performance Audit Findings: Material Weakness, Other Matters Condition and Context During the audit period, the School Corporation was a member of the Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For Special Education Cluster awards, funds must be obligated during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. When testing transactions which occurred in the liquidation period for the 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, and 22619-047-ARP grant awards, two exceptions were identified in the initial sample of five transactions. When expanding the sample, a third exception was noted, and it was concluded that it would not be appropriate to examine the remaining 14 transactions. For the above listed awards, costs must be obligated by September 30, 2023. For the three identified exceptions, an initial purchase order was made in September, but the ultimate transaction was paid to a separate vendor than the original purchase order, and this obligation was incurred in November 2023. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 22 NORTH NEWTON SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.403(h) states: "Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3)." 34 CFR 76.707 states in part: ". . . If the obligation is for- . . . (d) Performance of work other than personal services. . . . The obligation is made- On the date on which the State or subgrantee makes a binding written commitment to acquire the property. . . ." 2 CFR 200.1 states in part: ". . . Period of Performance means the total estimated time interval between the start of an initial Federal award and the planned end date . . ." 36 CFR 76.709(a) states: "If a State or a subgrantee does not obligate all of its grant or subgrant funds by the end of the fiscal year for which Congress appropriated the funds, it may obligate the remaining funds during a carryover period of one additional fiscal year." Cause Management had established an initial obligation date that occurred in September of the second fiscal year but modified the final vendor for payment. The new obligation occurred after the period in which the School Corporation was allowed to incur the expense. Effect If funds are not obligated by the end of the specified date, the grantor agency is not obligated to reimburse the School Corporation for costs incurred. This may indicate that the funding that was reimbursed, which incurred outside of the period of performance, will need to be repaid to the grantor agency, and the School Corporation will then need to support the costs with nonfederal funding. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that no costs are incurred after the September 30 deadline and to ensure compliance with the grant agreement and the Period of Performance compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: Special Education Cluster (IDEA) - Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, 22619-047-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Period of Performance Audit Findings: Material Weakness, Other Matters Condition and Context During the audit period, the School Corporation was a member of the Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For Special Education Cluster awards, funds must be obligated during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. When testing transactions which occurred in the liquidation period for the 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, and 22619-047-ARP grant awards, two exceptions were identified in the initial sample of five transactions. When expanding the sample, a third exception was noted, and it was concluded that it would not be appropriate to examine the remaining 14 transactions. For the above listed awards, costs must be obligated by September 30, 2023. For the three identified exceptions, an initial purchase order was made in September, but the ultimate transaction was paid to a separate vendor than the original purchase order, and this obligation was incurred in November 2023. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 22 NORTH NEWTON SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.403(h) states: "Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3)." 34 CFR 76.707 states in part: ". . . If the obligation is for- . . . (d) Performance of work other than personal services. . . . The obligation is made- On the date on which the State or subgrantee makes a binding written commitment to acquire the property. . . ." 2 CFR 200.1 states in part: ". . . Period of Performance means the total estimated time interval between the start of an initial Federal award and the planned end date . . ." 36 CFR 76.709(a) states: "If a State or a subgrantee does not obligate all of its grant or subgrant funds by the end of the fiscal year for which Congress appropriated the funds, it may obligate the remaining funds during a carryover period of one additional fiscal year." Cause Management had established an initial obligation date that occurred in September of the second fiscal year but modified the final vendor for payment. The new obligation occurred after the period in which the School Corporation was allowed to incur the expense. Effect If funds are not obligated by the end of the specified date, the grantor agency is not obligated to reimburse the School Corporation for costs incurred. This may indicate that the funding that was reimbursed, which incurred outside of the period of performance, will need to be repaid to the grantor agency, and the School Corporation will then need to support the costs with nonfederal funding. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that no costs are incurred after the September 30 deadline and to ensure compliance with the grant agreement and the Period of Performance compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: Special Education Cluster (IDEA) - Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, 22619-047-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Period of Performance Audit Findings: Material Weakness, Other Matters Condition and Context During the audit period, the School Corporation was a member of the Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For Special Education Cluster awards, funds must be obligated during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. When testing transactions which occurred in the liquidation period for the 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, and 22619-047-ARP grant awards, two exceptions were identified in the initial sample of five transactions. When expanding the sample, a third exception was noted, and it was concluded that it would not be appropriate to examine the remaining 14 transactions. For the above listed awards, costs must be obligated by September 30, 2023. For the three identified exceptions, an initial purchase order was made in September, but the ultimate transaction was paid to a separate vendor than the original purchase order, and this obligation was incurred in November 2023. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 22 NORTH NEWTON SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.403(h) states: "Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3)." 34 CFR 76.707 states in part: ". . . If the obligation is for- . . . (d) Performance of work other than personal services. . . . The obligation is made- On the date on which the State or subgrantee makes a binding written commitment to acquire the property. . . ." 2 CFR 200.1 states in part: ". . . Period of Performance means the total estimated time interval between the start of an initial Federal award and the planned end date . . ." 36 CFR 76.709(a) states: "If a State or a subgrantee does not obligate all of its grant or subgrant funds by the end of the fiscal year for which Congress appropriated the funds, it may obligate the remaining funds during a carryover period of one additional fiscal year." Cause Management had established an initial obligation date that occurred in September of the second fiscal year but modified the final vendor for payment. The new obligation occurred after the period in which the School Corporation was allowed to incur the expense. Effect If funds are not obligated by the end of the specified date, the grantor agency is not obligated to reimburse the School Corporation for costs incurred. This may indicate that the funding that was reimbursed, which incurred outside of the period of performance, will need to be repaid to the grantor agency, and the School Corporation will then need to support the costs with nonfederal funding. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that no costs are incurred after the September 30 deadline and to ensure compliance with the grant agreement and the Period of Performance compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: Special Education Cluster (IDEA) - Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, 22619-047-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Period of Performance Audit Findings: Material Weakness, Other Matters Condition and Context During the audit period, the School Corporation was a member of the Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For Special Education Cluster awards, funds must be obligated during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. When testing transactions which occurred in the liquidation period for the 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, and 22619-047-ARP grant awards, two exceptions were identified in the initial sample of five transactions. When expanding the sample, a third exception was noted, and it was concluded that it would not be appropriate to examine the remaining 14 transactions. For the above listed awards, costs must be obligated by September 30, 2023. For the three identified exceptions, an initial purchase order was made in September, but the ultimate transaction was paid to a separate vendor than the original purchase order, and this obligation was incurred in November 2023. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 22 NORTH NEWTON SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.403(h) states: "Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3)." 34 CFR 76.707 states in part: ". . . If the obligation is for- . . . (d) Performance of work other than personal services. . . . The obligation is made- On the date on which the State or subgrantee makes a binding written commitment to acquire the property. . . ." 2 CFR 200.1 states in part: ". . . Period of Performance means the total estimated time interval between the start of an initial Federal award and the planned end date . . ." 36 CFR 76.709(a) states: "If a State or a subgrantee does not obligate all of its grant or subgrant funds by the end of the fiscal year for which Congress appropriated the funds, it may obligate the remaining funds during a carryover period of one additional fiscal year." Cause Management had established an initial obligation date that occurred in September of the second fiscal year but modified the final vendor for payment. The new obligation occurred after the period in which the School Corporation was allowed to incur the expense. Effect If funds are not obligated by the end of the specified date, the grantor agency is not obligated to reimburse the School Corporation for costs incurred. This may indicate that the funding that was reimbursed, which incurred outside of the period of performance, will need to be repaid to the grantor agency, and the School Corporation will then need to support the costs with nonfederal funding. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that no costs are incurred after the September 30 deadline and to ensure compliance with the grant agreement and the Period of Performance compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: Special Education Cluster (IDEA) - Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, 22619-047-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Period of Performance Audit Findings: Material Weakness, Other Matters Condition and Context During the audit period, the School Corporation was a member of the Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For Special Education Cluster awards, funds must be obligated during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. When testing transactions which occurred in the liquidation period for the 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, and 22619-047-ARP grant awards, two exceptions were identified in the initial sample of five transactions. When expanding the sample, a third exception was noted, and it was concluded that it would not be appropriate to examine the remaining 14 transactions. For the above listed awards, costs must be obligated by September 30, 2023. For the three identified exceptions, an initial purchase order was made in September, but the ultimate transaction was paid to a separate vendor than the original purchase order, and this obligation was incurred in November 2023. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 22 NORTH NEWTON SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.403(h) states: "Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3)." 34 CFR 76.707 states in part: ". . . If the obligation is for- . . . (d) Performance of work other than personal services. . . . The obligation is made- On the date on which the State or subgrantee makes a binding written commitment to acquire the property. . . ." 2 CFR 200.1 states in part: ". . . Period of Performance means the total estimated time interval between the start of an initial Federal award and the planned end date . . ." 36 CFR 76.709(a) states: "If a State or a subgrantee does not obligate all of its grant or subgrant funds by the end of the fiscal year for which Congress appropriated the funds, it may obligate the remaining funds during a carryover period of one additional fiscal year." Cause Management had established an initial obligation date that occurred in September of the second fiscal year but modified the final vendor for payment. The new obligation occurred after the period in which the School Corporation was allowed to incur the expense. Effect If funds are not obligated by the end of the specified date, the grantor agency is not obligated to reimburse the School Corporation for costs incurred. This may indicate that the funding that was reimbursed, which incurred outside of the period of performance, will need to be repaid to the grantor agency, and the School Corporation will then need to support the costs with nonfederal funding. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that no costs are incurred after the September 30 deadline and to ensure compliance with the grant agreement and the Period of Performance compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024 -007 - Noncompliance with Period of Performance Requirements State Entity: University of Louisiana at Lafayette (UL Lafayette) Award Years: 2021, 2022 Award Numbers: 80NSSC21M0165, DE-FE0031919 Compliance Requirement: Period of Performance Repeat Finding: No See Schedule of Findings and Questioned Costs for chart/table. Condition: UL Lafayette did not ensure that all expenses charged to federal Research and Development (R&D) awards complied with the period of performance requirements. From a population of 166 R&D grants with expenses totaling $6,720,454 and periods of performance starting or ending during the fiscal year ending June 30, 2024, a non-statistical sample of 17 grants was tested for compliance with period of performance requirements. For two (11.8%) of the 17 grants tested, expenses totaling $63,790 were identified as noncompliant with the period of performance requirements. One grant had expenses totaling $28,833 that were incurred after the period of performance. For the other grant, UL Lafayette failed to liquidate obligations totaling $34,957 incurred during the period of performance within 120 days after the end the period of performance as required by federal regulations. Criteria: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance [2 CFR sections 200.308, 200.309, and 200.403(h)]. Additionally, 2 CFR 200.344 states that the recipient must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the conclusion of the period of performance. Cause: UL Lafayette did not have sufficient internal controls to ensure that only expenses incurred during the period of performance were charged to R&D grants and that obligations were liquidated timely. Effect: Noncompliance with the period of performance requirements resulted in $63,790 in questioned costs and increases the risk that expenses could be disallowed and not reimbursed by the awarding agency. Recommendation: Management should strengthen their procedures and internal controls that are in place to ensure that all expenses incurred on federal R&D grants comply with the period of performance requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-62).
2024-006 - Control Weakness and Noncompliance with Personnel Expenses Charged to Federal Awards State Entity: University of Louisiana at Lafayette (UL Lafayette) Award Years: 2020, 2021, 2022 Award Numbers: 1R01MH125395, 2046460, R37AI094595 Compliance Requirements: Allowable Costs/Cost Principles; Special Tests and Provisions Pass-Through Entity: Northwestern University Repeat Finding: Yes (Prior Year Finding No. 2023-007) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the fourth consecutive year, the University of Louisiana at Lafayette (UL Lafayette) did not have adequate controls in place to ensure personnel expenses charged to federal Research and Development (R&D) awards accurately reflected work performed. From a population of 14,024 payroll and non-payroll expenses charged to R&D grants for the fiscal year ending June 30, 2024, a non-statistical sample of 25 transactions were tested for compliance with allowable costs and cost principles requirements. For three (12%) of the payroll transactions, UL Lafayette was unable to provide documentation to show that personnel-related expenses totaling $18,707 were supported by time and effort certifications to ensure the accuracy of budget estimates charged to federal awards as required by federal regulations. Additionally, UL Lafayette did not perform time and effort certifications for the period January 1, 2024, through June 30, 2024. Because there is no after-the-fact review to ensure the accuracy of personnel costs and efforts charged to the awards, UL Lafayette could not ensure compliance with the requirements of special tests and provisions related to key personnel effort. Criteria: 2 CFR 200.430(i) specifies the documentation standards for personnel expenses. In order to be allowable, charges to federal awards for personnel expenses must be based on records that accurately reflect the work performed and must be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates alone do not qualify as support for charges to federal awards, but can be used for interim accounting purposes provided that internal controls include an after-the fact review to confirm the accuracy of final amounts charged to federal awards. Prior approval requirements related to key personnel effort are contained in 2 CFR 200.308(c) and within grant terms and conditions. A reduction of 25% or greater in time devoted to the project from key personnel requires prior approval, as does disengagement of key personnel from the project for three or more months. Cause: UL Lafayette noted in their prior-year corrective action that certifications for employees charging time to federal awards would be required annually. Annual certifications are not sufficient to timely detect changes in key personnel effort and ensure prior approvals are obtained when applicable. Furthermore, UL Lafayette noted that the next effort reporting cycle would cover July 1, 2023, through December 31, 2023. The time certification period only covered half of the audit period. As a result, time and effort certifications were not completed by employees on the latter half of the audit period to support that the charges to federal awards for salaries and wages were based on records that accurately reflect the work performed during this period. Effect: Inadequate controls related to federal documentation standards for personnel expenses could result in noncompliance with federal allowable costs and cost principles, as well as noncompliance with special tests and provisions related to key personnel effort. Recommendation: Management should strengthen internal controls to ensure that personnel expenses charged to the federal awards are supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Additionally, Management should revise the Time & Effort Certification policy and/or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management should monitor changes in effort for key personnel and ensure that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management’s Response and Corrective Action Plan: Management partially concurred with the finding and provided a corrective action plan (B-60).
2024 -007 - Noncompliance with Period of Performance Requirements State Entity: University of Louisiana at Lafayette (UL Lafayette) Award Years: 2021, 2022 Award Numbers: 80NSSC21M0165, DE-FE0031919 Compliance Requirement: Period of Performance Repeat Finding: No See Schedule of Findings and Questioned Costs for chart/table. Condition: UL Lafayette did not ensure that all expenses charged to federal Research and Development (R&D) awards complied with the period of performance requirements. From a population of 166 R&D grants with expenses totaling $6,720,454 and periods of performance starting or ending during the fiscal year ending June 30, 2024, a non-statistical sample of 17 grants was tested for compliance with period of performance requirements. For two (11.8%) of the 17 grants tested, expenses totaling $63,790 were identified as noncompliant with the period of performance requirements. One grant had expenses totaling $28,833 that were incurred after the period of performance. For the other grant, UL Lafayette failed to liquidate obligations totaling $34,957 incurred during the period of performance within 120 days after the end the period of performance as required by federal regulations. Criteria: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance [2 CFR sections 200.308, 200.309, and 200.403(h)]. Additionally, 2 CFR 200.344 states that the recipient must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the conclusion of the period of performance. Cause: UL Lafayette did not have sufficient internal controls to ensure that only expenses incurred during the period of performance were charged to R&D grants and that obligations were liquidated timely. Effect: Noncompliance with the period of performance requirements resulted in $63,790 in questioned costs and increases the risk that expenses could be disallowed and not reimbursed by the awarding agency. Recommendation: Management should strengthen their procedures and internal controls that are in place to ensure that all expenses incurred on federal R&D grants comply with the period of performance requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-62).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-006 - Control Weakness and Noncompliance with Personnel Expenses Charged to Federal Awards State Entity: University of Louisiana at Lafayette (UL Lafayette) Award Years: 2020, 2021, 2022 Award Numbers: 1R01MH125395, 2046460, R37AI094595 Compliance Requirements: Allowable Costs/Cost Principles; Special Tests and Provisions Pass-Through Entity: Northwestern University Repeat Finding: Yes (Prior Year Finding No. 2023-007) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the fourth consecutive year, the University of Louisiana at Lafayette (UL Lafayette) did not have adequate controls in place to ensure personnel expenses charged to federal Research and Development (R&D) awards accurately reflected work performed. From a population of 14,024 payroll and non-payroll expenses charged to R&D grants for the fiscal year ending June 30, 2024, a non-statistical sample of 25 transactions were tested for compliance with allowable costs and cost principles requirements. For three (12%) of the payroll transactions, UL Lafayette was unable to provide documentation to show that personnel-related expenses totaling $18,707 were supported by time and effort certifications to ensure the accuracy of budget estimates charged to federal awards as required by federal regulations. Additionally, UL Lafayette did not perform time and effort certifications for the period January 1, 2024, through June 30, 2024. Because there is no after-the-fact review to ensure the accuracy of personnel costs and efforts charged to the awards, UL Lafayette could not ensure compliance with the requirements of special tests and provisions related to key personnel effort. Criteria: 2 CFR 200.430(i) specifies the documentation standards for personnel expenses. In order to be allowable, charges to federal awards for personnel expenses must be based on records that accurately reflect the work performed and must be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates alone do not qualify as support for charges to federal awards, but can be used for interim accounting purposes provided that internal controls include an after-the fact review to confirm the accuracy of final amounts charged to federal awards. Prior approval requirements related to key personnel effort are contained in 2 CFR 200.308(c) and within grant terms and conditions. A reduction of 25% or greater in time devoted to the project from key personnel requires prior approval, as does disengagement of key personnel from the project for three or more months. Cause: UL Lafayette noted in their prior-year corrective action that certifications for employees charging time to federal awards would be required annually. Annual certifications are not sufficient to timely detect changes in key personnel effort and ensure prior approvals are obtained when applicable. Furthermore, UL Lafayette noted that the next effort reporting cycle would cover July 1, 2023, through December 31, 2023. The time certification period only covered half of the audit period. As a result, time and effort certifications were not completed by employees on the latter half of the audit period to support that the charges to federal awards for salaries and wages were based on records that accurately reflect the work performed during this period. Effect: Inadequate controls related to federal documentation standards for personnel expenses could result in noncompliance with federal allowable costs and cost principles, as well as noncompliance with special tests and provisions related to key personnel effort. Recommendation: Management should strengthen internal controls to ensure that personnel expenses charged to the federal awards are supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Additionally, Management should revise the Time & Effort Certification policy and/or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management should monitor changes in effort for key personnel and ensure that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management’s Response and Corrective Action Plan: Management partially concurred with the finding and provided a corrective action plan (B-60).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-006 - Control Weakness and Noncompliance with Personnel Expenses Charged to Federal Awards State Entity: University of Louisiana at Lafayette (UL Lafayette) Award Years: 2020, 2021, 2022 Award Numbers: 1R01MH125395, 2046460, R37AI094595 Compliance Requirements: Allowable Costs/Cost Principles; Special Tests and Provisions Pass-Through Entity: Northwestern University Repeat Finding: Yes (Prior Year Finding No. 2023-007) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the fourth consecutive year, the University of Louisiana at Lafayette (UL Lafayette) did not have adequate controls in place to ensure personnel expenses charged to federal Research and Development (R&D) awards accurately reflected work performed. From a population of 14,024 payroll and non-payroll expenses charged to R&D grants for the fiscal year ending June 30, 2024, a non-statistical sample of 25 transactions were tested for compliance with allowable costs and cost principles requirements. For three (12%) of the payroll transactions, UL Lafayette was unable to provide documentation to show that personnel-related expenses totaling $18,707 were supported by time and effort certifications to ensure the accuracy of budget estimates charged to federal awards as required by federal regulations. Additionally, UL Lafayette did not perform time and effort certifications for the period January 1, 2024, through June 30, 2024. Because there is no after-the-fact review to ensure the accuracy of personnel costs and efforts charged to the awards, UL Lafayette could not ensure compliance with the requirements of special tests and provisions related to key personnel effort. Criteria: 2 CFR 200.430(i) specifies the documentation standards for personnel expenses. In order to be allowable, charges to federal awards for personnel expenses must be based on records that accurately reflect the work performed and must be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates alone do not qualify as support for charges to federal awards, but can be used for interim accounting purposes provided that internal controls include an after-the fact review to confirm the accuracy of final amounts charged to federal awards. Prior approval requirements related to key personnel effort are contained in 2 CFR 200.308(c) and within grant terms and conditions. A reduction of 25% or greater in time devoted to the project from key personnel requires prior approval, as does disengagement of key personnel from the project for three or more months. Cause: UL Lafayette noted in their prior-year corrective action that certifications for employees charging time to federal awards would be required annually. Annual certifications are not sufficient to timely detect changes in key personnel effort and ensure prior approvals are obtained when applicable. Furthermore, UL Lafayette noted that the next effort reporting cycle would cover July 1, 2023, through December 31, 2023. The time certification period only covered half of the audit period. As a result, time and effort certifications were not completed by employees on the latter half of the audit period to support that the charges to federal awards for salaries and wages were based on records that accurately reflect the work performed during this period. Effect: Inadequate controls related to federal documentation standards for personnel expenses could result in noncompliance with federal allowable costs and cost principles, as well as noncompliance with special tests and provisions related to key personnel effort. Recommendation: Management should strengthen internal controls to ensure that personnel expenses charged to the federal awards are supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Additionally, Management should revise the Time & Effort Certification policy and/or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management should monitor changes in effort for key personnel and ensure that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management’s Response and Corrective Action Plan: Management partially concurred with the finding and provided a corrective action plan (B-60).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-004 – Noncompliance and Weakness in Controls with Special Tests and Provisions Requirements State Entity: Louisiana State University Health Sciences Center - Shreveport (LSUHSC-S) Award Years: Various Award Numbers: Various Compliance Requirement: Special Tests and Provisions Pass-Through Entities: Various Repeat Finding: Yes (Prior Year Finding No. 2023-029) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the sixth consecutive year, Louisiana State University Health Sciences Center in Shreveport (LSUHSC-S) did not have adequate controls in place to ensure compliance with Special Tests and Provisions requirements. We reviewed a non-statistical sample of 12 federal Research and Development Cluster awards from a population of 61 awards, plus two additional awards based on materiality, for the fiscal year ending June 30, 2024. We reviewed the biannual Time and Effort Certification forms, as applicable, for each award and the 27 key personnel assigned to the selected awards. We noted two of 27 (7.4%) key personnel had documentation indicating that the key personnel were removed from the grant and/or had documentation of actual effort on the Time and Effort Certification forms that did not agree to the effort reported to the federal grantor. There was also no evidence of prior approval from the federal grantor for a change in key personnel. Criteria: 2 CFR 200.308(f) states that a recipient or subrecipient must request prior written approval from the federal agency or pass-through entity for the following program and budget-related reasons: • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval). • Change in key personnel (including employees and contractors) that are identified by name or position in the federal award. • The disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award over the course of the period of performance, by the approved project director or principal investigator. Cause: LSUHSC-S’s controls are not effectively designed to ensure prior approval is obtained for changes in effort by key personnel as required by federal regulations, specifically relating to disengagement from a project for more than three months or a 25% reduction in effort. This is partially due to LSUHSC-S revising its Time & Effort Certification policy in September 2022, which changed the frequency of the certification from quarterly to semiannually. Effect: Failure to implement controls over key personnel requirements could result in noncompliance with Special Tests and Provisions requirements. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests and Provisions requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-45).
2024-007 – Period of Performance Federal Agency: National Science Foundation and U.S. Department of Education Federal Program Title: Research and Development Cluster Federal Assistance Listing Numbers: 84.017 and 47.081 Federal Award Identification Number and Year: Various Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Two grants were identified as having ended in a prior year but were still incurring expenditures that are included on the SEFA in fiscal year 2024. Questioned Costs: N/A Context: During the testing of the SEFA for the period, it was noted that two of the grants tested had end dates before the beginning of the fiscal year (7/1/2023) but had costs incurred and reported on the SEFA for fiscal year 2024. The University did not receive extensions on these grants. Cause: Internal controls ensuring that costs are not reported on the SEFA after the end of the period of performance were not functioning as designed. Effect: The current year SEFA included expenses that were incurred after the grant ended. Repeat Finding: No. Recommendation: We recommend that the University review and revise their current procedures in place and provide training to employees within the grant and finance functions related to the grant reconciliation and recording process to ensure expenses are reflected prior to the grant ending and recorded in the correct period on the SEFA. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2024-007 – Period of Performance Federal Agency: National Science Foundation and U.S. Department of Education Federal Program Title: Research and Development Cluster Federal Assistance Listing Numbers: 84.017 and 47.081 Federal Award Identification Number and Year: Various Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Two grants were identified as having ended in a prior year but were still incurring expenditures that are included on the SEFA in fiscal year 2024. Questioned Costs: N/A Context: During the testing of the SEFA for the period, it was noted that two of the grants tested had end dates before the beginning of the fiscal year (7/1/2023) but had costs incurred and reported on the SEFA for fiscal year 2024. The University did not receive extensions on these grants. Cause: Internal controls ensuring that costs are not reported on the SEFA after the end of the period of performance were not functioning as designed. Effect: The current year SEFA included expenses that were incurred after the grant ended. Repeat Finding: No. Recommendation: We recommend that the University review and revise their current procedures in place and provide training to employees within the grant and finance functions related to the grant reconciliation and recording process to ensure expenses are reflected prior to the grant ending and recorded in the correct period on the SEFA. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
Cluster: Not applicable Sponsoring Agency: Department of Health and Human Services Award Names: Substance Use Disorder Treatment and Recovery Award Numbers: Cheshire Medical Center 2019-BDAS-05-ACCES-04, 05-95-92-920510-7040-5007, RFP-2018-BDAS-05-INTEG Assistance Listing Title: Opioid STR Assistance Listing Number: 93.788 Award Year: 2023-2024 Pass-through entity: New Hampshire Department of Health and Human Services Criteria 2 CFR 200.308 Revision of budget and program plans requires a recipient or subrecipient to request prior written approval from the Federal agency or pass-through entity for changes in key personnel (including employees and contractors) that are identified by name or position in the Federal award. Additionally, the terms of the Opioid STR award agreements at Cheshire Medical Center require changes in staffing, whether temporary or long term, to be provided to the New Hampshire Department of Health and Human Services (DHHS) for approval, 30 calendar days before making the change. Condition In testing conformity with the compliance requirements for key personnel, we selected 4 of the key personnel changes that occurred on the Cheshire Medical Center Opioid STR awards which included key personnel that changed roles or resigned from the System in fiscal year 2024. Management identified replacement key personnel to participate in the grant; however, management did not notify DHHS and did not obtain approval from DHHS regarding the changes. Cause Management did not have a control in place to notify DHHS and request approval for key personnel changes. Effect The granting agency was unaware of key changes made to personnel on the award and may have not concurred with the individual selected to fill the given role(s). Questioned Costs None noted. Recommendation We recommend that management communicate with their agency contacts regarding this matter and implement a control that monitors the key personnel assigned to the grant to ensure that they are notifying the agency of any changes in status and obtaining approval from the agency in a timely manner.
Cluster: Not applicable Sponsoring Agency: Department of Health and Human Services Award Names: Substance Use Disorder Treatment and Recovery Award Numbers: Cheshire Medical Center 2019-BDAS-05-ACCES-04, 05-95-92-920510-7040-5007, RFP-2018-BDAS-05-INTEG Assistance Listing Title: Opioid STR Assistance Listing Number: 93.788 Award Year: 2023-2024 Pass-through entity: New Hampshire Department of Health and Human Services Criteria 2 CFR 200.308 Revision of budget and program plans requires a recipient or subrecipient to request prior written approval from the Federal agency or pass-through entity for changes in key personnel (including employees and contractors) that are identified by name or position in the Federal award. Additionally, the terms of the Opioid STR award agreements at Cheshire Medical Center require changes in staffing, whether temporary or long term, to be provided to the New Hampshire Department of Health and Human Services (DHHS) for approval, 30 calendar days before making the change. Condition In testing conformity with the compliance requirements for key personnel, we selected 4 of the key personnel changes that occurred on the Cheshire Medical Center Opioid STR awards which included key personnel that changed roles or resigned from the System in fiscal year 2024. Management identified replacement key personnel to participate in the grant; however, management did not notify DHHS and did not obtain approval from DHHS regarding the changes. Cause Management did not have a control in place to notify DHHS and request approval for key personnel changes. Effect The granting agency was unaware of key changes made to personnel on the award and may have not concurred with the individual selected to fill the given role(s). Questioned Costs None noted. Recommendation We recommend that management communicate with their agency contacts regarding this matter and implement a control that monitors the key personnel assigned to the grant to ensure that they are notifying the agency of any changes in status and obtaining approval from the agency in a timely manner.
Cluster: Not applicable Sponsoring Agency: Department of Health and Human Services Award Names: Substance Use Disorder Treatment and Recovery Award Numbers: Cheshire Medical Center 2019-BDAS-05-ACCES-04, 05-95-92-920510-7040-5007, RFP-2018-BDAS-05-INTEG Assistance Listing Title: Opioid STR Assistance Listing Number: 93.788 Award Year: 2023-2024 Pass-through entity: New Hampshire Department of Health and Human Services Criteria 2 CFR 200.308 Revision of budget and program plans requires a recipient or subrecipient to request prior written approval from the Federal agency or pass-through entity for changes in key personnel (including employees and contractors) that are identified by name or position in the Federal award. Additionally, the terms of the Opioid STR award agreements at Cheshire Medical Center require changes in staffing, whether temporary or long term, to be provided to the New Hampshire Department of Health and Human Services (DHHS) for approval, 30 calendar days before making the change. Condition In testing conformity with the compliance requirements for key personnel, we selected 4 of the key personnel changes that occurred on the Cheshire Medical Center Opioid STR awards which included key personnel that changed roles or resigned from the System in fiscal year 2024. Management identified replacement key personnel to participate in the grant; however, management did not notify DHHS and did not obtain approval from DHHS regarding the changes. Cause Management did not have a control in place to notify DHHS and request approval for key personnel changes. Effect The granting agency was unaware of key changes made to personnel on the award and may have not concurred with the individual selected to fill the given role(s). Questioned Costs None noted. Recommendation We recommend that management communicate with their agency contacts regarding this matter and implement a control that monitors the key personnel assigned to the grant to ensure that they are notifying the agency of any changes in status and obtaining approval from the agency in a timely manner.
Finding No. 2024-003 Assistance Listing Program Title and Number: 64.033 Supportive Services for Veteran Families Criteria 2 CFR § 200.308, 200.309 and 200.403(h)) A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity. Condition During period of performance testing for the Supportive Services for Veteran Families (SSVF) Program, eight instances were identified where expenses were incurred outside of the allowable timeframe. Cause This noncompliance may have resulted from inadequate controls to validate expense dates during approval and/or lack of staff training on period-of-performance requirements Effect There is an increased audit risk for federal fund misuse and a potential for unallowable expense reimbursement repayment. Recommendation 1. Implement pre-approval controls: Require date validation for all expenses against the award’s period of performance. 2. Conduct training: Educate staff on 2 CFR requirements and period-of-performance limitations. 3. Perform periodic reviews: Monitor compliance quarterly to detect outliers. Management’s Response Management agrees with this finding, see the Corrective Action Plan.