Cluster: Research and Development Federal Agency: Various Award Names: Various Award Numbers: Various Assistance Listing Title: Various Assistance Listing Number: Various Award Year: 2023- 2024 Pass-through entity: Various Criteria According to 2 CFR section 200.313, procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, at a minimum, meet the following requirements: (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the non-Federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. Condition The Dartmouth Health System did not have a process in place to ensure that all federally funded equipment included in the fixed asset register were included in its clinical engineering database where monitoring of federally funded equipment is tracked. As a result, while inspection was completed over 3 federal assets in FY2024, the Dartmouth Health System has not completed a physical inventory of all federally purchased fixed assets at least once during the last two years. Additionally, the federal asset listing did not specify all of the details required by 2 CFR section 200.313 (d) (1) such as the percentage of Federal participation in the project costs for the Federal award under which the property was acquired, asset location and the use and condition of the equipment. The full population of equipment funded with federal research and development dollars, as provided by the Dartmouth Health System, consisted of 15 items with a total historical cost of $122.6k. Cause In FY2024, the Dartmouth Health System was in progress implementing its corrective action plan with respect to the finding identified in FY2022, including creating a federal equipment tracking procedure, inspecting identified federal assets and updating property records to include details required by 2 CFR section 200.313. As the corrective action plan was not fully implemented by the end of FY2024, all compliance requirements with respect to federal equipment were not yet satisfied. Effect The Dartmouth Health System's accounting records for its federally purchased fixed assets could be inaccurate as the Dartmouth Health System has not formally verified the existence, current utilization and continued need for all federally funded equipment through this physical inventory process. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System implement a process to ensure its policies and procedures over equipment management are followed, including the performance of a physical inventory of federally purchased fixed assets at least once every two years in accordance with 2 CFR section 200.313(d)(2), updating its property records to include all details required by 2 CFR section 200.313(d)(1) and performing a reconciliation between the listing of federally purchased fixed assets and the full fixed asset register to ensure completeness.
Cluster: Research and Development Federal Agency: Various Award Names: Various Award Numbers: Various Assistance Listing Title: Various Assistance Listing Number: Various Award Year: 2023- 2024 Pass-through entity: Various Criteria According to 2 CFR section 200.313, procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, at a minimum, meet the following requirements: (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the non-Federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. Condition The Dartmouth Health System did not have a process in place to ensure that all federally funded equipment included in the fixed asset register were included in its clinical engineering database where monitoring of federally funded equipment is tracked. As a result, while inspection was completed over 3 federal assets in FY2024, the Dartmouth Health System has not completed a physical inventory of all federally purchased fixed assets at least once during the last two years. Additionally, the federal asset listing did not specify all of the details required by 2 CFR section 200.313 (d) (1) such as the percentage of Federal participation in the project costs for the Federal award under which the property was acquired, asset location and the use and condition of the equipment. The full population of equipment funded with federal research and development dollars, as provided by the Dartmouth Health System, consisted of 15 items with a total historical cost of $122.6k. Cause In FY2024, the Dartmouth Health System was in progress implementing its corrective action plan with respect to the finding identified in FY2022, including creating a federal equipment tracking procedure, inspecting identified federal assets and updating property records to include details required by 2 CFR section 200.313. As the corrective action plan was not fully implemented by the end of FY2024, all compliance requirements with respect to federal equipment were not yet satisfied. Effect The Dartmouth Health System's accounting records for its federally purchased fixed assets could be inaccurate as the Dartmouth Health System has not formally verified the existence, current utilization and continued need for all federally funded equipment through this physical inventory process. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System implement a process to ensure its policies and procedures over equipment management are followed, including the performance of a physical inventory of federally purchased fixed assets at least once every two years in accordance with 2 CFR section 200.313(d)(2), updating its property records to include all details required by 2 CFR section 200.313(d)(1) and performing a reconciliation between the listing of federally purchased fixed assets and the full fixed asset register to ensure completeness.
Develop Written Policies and Procedures Criteria: 2 CFR 200.303 requires nonfederal entities to establish and maintain effective internal control over federal awards to provide reasonable assurance that organizations who manage the federal award: • Understand and comply with the federal statutes, regulations, and terms and conditions of the award; • Evaluate and monitor compliance; • Take prompt action when instances of noncompliance is identified. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government, issued by the Comptroller General of the United States, or the Internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Additionally, the Uniform Guidance requires non-federal entities to develop written procedures related to the following areas: 1. Cash Management 2 CFR 200.302(b)(6) states that the financial management system of each non-Federal entity must provide for the written procedures to implement the requirements of 2 CFR 200.305 Federal Payment. 2. Equipment Management Requirements Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e). In addition, the organizations should ensure that existing written procedures are in compliance with: a. General Procurement Standards 2 CFR 200.318 to 200.327 discusses that contracts must be established and managed in accordance with the procurement requirements in 2 CFR Part 200. Grantees must have written procurement policies and procedures that demonstrate a fair and reliable process, with standards of conduct addressing conflicts of interest, for obtaining grant-funded goods and services. Condition MARTA does not have comprehensive written policies and procedures concerning the following key compliance areas which are required by the Uniform Guidance: Equipment and Real Property Management MARTA has an Asset Inventory Policy and Procedures, however, it does not clearly define the policies and procedures that are in place for the use, management and disposition of equipment acquired under a Federal award in accordance with 2 CFR sections 200.313(c) through (e). Cash Management MARTA does not have written procedures to implement the requirements of 2 CFR 200.305 Federal Payment. Procurement, Suspension and Debarment MARTA has a Procurement policy, however, documented procedures are not well-defined regarding the purchase process for different types of procurement, obtaining quotations, bidding, and procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Cause MARTA’s reliance on informal business practices leads to inconsistencies in its internal controls. Effect The absence of formal policies and procedures in the key compliance areas could result in non-compliance with federal regulations, which may lead to unnecessary sanctions. Additionally, without formal written policies and procedures, it is difficult to ensure consistent practices across the organization. Questioned Costs None Recommendation MARTA should develop and implement formal written policies and procedures for the specific areas required by the Uniform Guidance. These policies and procedures must clearly delineate the requirements of the Uniform Guidance. Personnel responsible for these areas should receive adequate training and apply the policies effectively. Regular reviews should be conducted to update the policies and procedures as needed. Views of Responsible Officials and Planned Corrective Action MARTA has grown substantially in the last several years. This progress includes identifying areas that we need to update or to develop new processes and documentation. MARTA has an Asset Inventory Policy and Procedures in which the purpose is to ensure that fixed assets are properly accounted for, identified, and tracked. MARTA also has Cash Handling Policy and Procedures which addresses safeguarding public funds and maximizing resources available. This is designed to reduce the risks associated with the collection, receipts storage and reporting of cash transactions and to safeguard and maintain the security and integrity of MARTA's fiscal assets. MARTA is in the process of updating the Procurement Policy. MARTA will review and update these policies and/or create new policies to make sure that they are compliant with the Uniform Guidance. The updated or newly created policies will be brought to the October 2025 Board of Directors meeting for Board review or approval. Personnel responsible: Sandy Benson, General Manager Anticipated completion date: October 2025
Develop Written Policies and Procedures Criteria: 2 CFR 200.303 requires nonfederal entities to establish and maintain effective internal control over federal awards to provide reasonable assurance that organizations who manage the federal award: • Understand and comply with the federal statutes, regulations, and terms and conditions of the award; • Evaluate and monitor compliance; • Take prompt action when instances of noncompliance is identified. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government, issued by the Comptroller General of the United States, or the Internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Additionally, the Uniform Guidance requires non-federal entities to develop written procedures related to the following areas: 1. Cash Management 2 CFR 200.302(b)(6) states that the financial management system of each non-Federal entity must provide for the written procedures to implement the requirements of 2 CFR 200.305 Federal Payment. 2. Equipment Management Requirements Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e). In addition, the organizations should ensure that existing written procedures are in compliance with: a. General Procurement Standards 2 CFR 200.318 to 200.327 discusses that contracts must be established and managed in accordance with the procurement requirements in 2 CFR Part 200. Grantees must have written procurement policies and procedures that demonstrate a fair and reliable process, with standards of conduct addressing conflicts of interest, for obtaining grant-funded goods and services. Condition MARTA does not have comprehensive written policies and procedures concerning the following key compliance areas which are required by the Uniform Guidance: Equipment and Real Property Management MARTA has an Asset Inventory Policy and Procedures, however, it does not clearly define the policies and procedures that are in place for the use, management and disposition of equipment acquired under a Federal award in accordance with 2 CFR sections 200.313(c) through (e). Cash Management MARTA does not have written procedures to implement the requirements of 2 CFR 200.305 Federal Payment. Procurement, Suspension and Debarment MARTA has a Procurement policy, however, documented procedures are not well-defined regarding the purchase process for different types of procurement, obtaining quotations, bidding, and procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Cause MARTA’s reliance on informal business practices leads to inconsistencies in its internal controls. Effect The absence of formal policies and procedures in the key compliance areas could result in non-compliance with federal regulations, which may lead to unnecessary sanctions. Additionally, without formal written policies and procedures, it is difficult to ensure consistent practices across the organization. Questioned Costs None Recommendation MARTA should develop and implement formal written policies and procedures for the specific areas required by the Uniform Guidance. These policies and procedures must clearly delineate the requirements of the Uniform Guidance. Personnel responsible for these areas should receive adequate training and apply the policies effectively. Regular reviews should be conducted to update the policies and procedures as needed. Views of Responsible Officials and Planned Corrective Action MARTA has grown substantially in the last several years. This progress includes identifying areas that we need to update or to develop new processes and documentation. MARTA has an Asset Inventory Policy and Procedures in which the purpose is to ensure that fixed assets are properly accounted for, identified, and tracked. MARTA also has Cash Handling Policy and Procedures which addresses safeguarding public funds and maximizing resources available. This is designed to reduce the risks associated with the collection, receipts storage and reporting of cash transactions and to safeguard and maintain the security and integrity of MARTA's fiscal assets. MARTA is in the process of updating the Procurement Policy. MARTA will review and update these policies and/or create new policies to make sure that they are compliant with the Uniform Guidance. The updated or newly created policies will be brought to the October 2025 Board of Directors meeting for Board review or approval. Personnel responsible: Sandy Benson, General Manager Anticipated completion date: October 2025
Develop Written Policies and Procedures Criteria: 2 CFR 200.303 requires nonfederal entities to establish and maintain effective internal control over federal awards to provide reasonable assurance that organizations who manage the federal award: • Understand and comply with the federal statutes, regulations, and terms and conditions of the award; • Evaluate and monitor compliance; • Take prompt action when instances of noncompliance is identified. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government, issued by the Comptroller General of the United States, or the Internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Additionally, the Uniform Guidance requires non-federal entities to develop written procedures related to the following areas: 1. Cash Management 2 CFR 200.302(b)(6) states that the financial management system of each non-Federal entity must provide for the written procedures to implement the requirements of 2 CFR 200.305 Federal Payment. 2. Equipment Management Requirements Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e). In addition, the organizations should ensure that existing written procedures are in compliance with: a. General Procurement Standards 2 CFR 200.318 to 200.327 discusses that contracts must be established and managed in accordance with the procurement requirements in 2 CFR Part 200. Grantees must have written procurement policies and procedures that demonstrate a fair and reliable process, with standards of conduct addressing conflicts of interest, for obtaining grant-funded goods and services. Condition MARTA does not have comprehensive written policies and procedures concerning the following key compliance areas which are required by the Uniform Guidance: Equipment and Real Property Management MARTA has an Asset Inventory Policy and Procedures, however, it does not clearly define the policies and procedures that are in place for the use, management and disposition of equipment acquired under a Federal award in accordance with 2 CFR sections 200.313(c) through (e). Cash Management MARTA does not have written procedures to implement the requirements of 2 CFR 200.305 Federal Payment. Procurement, Suspension and Debarment MARTA has a Procurement policy, however, documented procedures are not well-defined regarding the purchase process for different types of procurement, obtaining quotations, bidding, and procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Cause MARTA’s reliance on informal business practices leads to inconsistencies in its internal controls. Effect The absence of formal policies and procedures in the key compliance areas could result in non-compliance with federal regulations, which may lead to unnecessary sanctions. Additionally, without formal written policies and procedures, it is difficult to ensure consistent practices across the organization. Questioned Costs None Recommendation MARTA should develop and implement formal written policies and procedures for the specific areas required by the Uniform Guidance. These policies and procedures must clearly delineate the requirements of the Uniform Guidance. Personnel responsible for these areas should receive adequate training and apply the policies effectively. Regular reviews should be conducted to update the policies and procedures as needed. Views of Responsible Officials and Planned Corrective Action MARTA has grown substantially in the last several years. This progress includes identifying areas that we need to update or to develop new processes and documentation. MARTA has an Asset Inventory Policy and Procedures in which the purpose is to ensure that fixed assets are properly accounted for, identified, and tracked. MARTA also has Cash Handling Policy and Procedures which addresses safeguarding public funds and maximizing resources available. This is designed to reduce the risks associated with the collection, receipts storage and reporting of cash transactions and to safeguard and maintain the security and integrity of MARTA's fiscal assets. MARTA is in the process of updating the Procurement Policy. MARTA will review and update these policies and/or create new policies to make sure that they are compliant with the Uniform Guidance. The updated or newly created policies will be brought to the October 2025 Board of Directors meeting for Board review or approval. Personnel responsible: Sandy Benson, General Manager Anticipated completion date: October 2025
New York City Police Department (“NYPD”) Finding #: 2024-006 Funding Year(s): 9/1/2019-8/31/2026 Rail and Transit Security Grant Program (FAL #97.075) Contract Number(s): EMW-2019-RA-00004, EMW-2020-RA-00005, EMW-2021-RA-00004, EMW- EMW-2022-RA-00006, EMW-2023-RA-00003 Federal Agency: U.S. Department of Homeland Security Type of Finding: Equipment and Real Property Management - Compliance and Internal Control (Significant Deficiency) Criteria: In accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Condition/Context: The New York City Police Department (“NYPD”) utilizes the City’s Grants Tracking System (“GTS”), a citywide web-based inventory program, designed to standardize the tracking of federally funded equipment. Further, NYPD Command-designated grants coordinators are responsible for monitoring the equipment and updating the inventory on a periodic basis in accordance with federal guidelines. The NYPD Grants Unit periodically generates an inventory listing from GTS that includes the biennial inventory count due date for each item and distributes it to the assigned NYPD Command designated grant coordinators to ensure the inventory count is conducted timely and in accordance with federal requirements. After the completion of biennial inventory count, the NYPD Command-designated grants coordinators update the inventory count information to GTS. From a non-statistical sample of thirteen (13) pieces of equipment subjected to testing, we identified one (1) piece of equipment that was disposed of prior to the most recent inventory count, but the equipment was not removed from the active inventory listing. Cause/Effect: While NYPD had certain procedures in place to monitor their equipment purchased with Federal funding, such procedures were not adequate to ensure that each aspect of the equipment and real property management compliance requirements were performed and documented within the required timeframe, which resulted in the finding noted above. Without the appropriate internal controls and monitoring procedures in place, federally funded equipment could be inaccurately recorded on inventory records and not discovered and corrected timely, inventory could be misplaced, misappropriated, or otherwise disposed of outside of the requirements of the federal guidelines. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that NYPD strengthen controls over the inventory process to ensure dispositions of equipment are updated in the equipment records.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.