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.
Assistance Listing Program Title and Number: Continuum of Care Program 14.267 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 Continuum of Care Program two instances were identified where expenses were incurred outside of the allowable timeframe. The sample size was extended to address this deficiency, and no additional exceptions were noted. 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.
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.