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”.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.
Finding 2024-006 – F. Equipment and Real Property Management Information on Federal Program(s) – Research and Development Cluster (ALN’s: Various) Criteria or Specific Requirement – Institutions that expend federal funds on equipment are required to conduct a physical inventory of the equipment at least once every 2 years and reconcile results of the count to the appropriate equipment records, as required by 2 CFR section 200.313(d)(2)). 2 CFR sections 200.313(c) and (e) requires that property records 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 Federal award identification number), who holds title, the acquisition date, 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 sales price of the property (collectively, the “Required Equipment Information”). Additionally, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – Though the University performed a physical inventory in the last 2 years, the University was unable to provide formal and complete documentation that the physical inventory was properly documented and was properly reconciled to the appropriate equipment records. The documentation consisted of physical count workpapers and was not organized or documented in a fashion that appeared to evidence that the count was complete and that the final count was reconciled to the University's equipment records. Additionally, the Required Equipment Information could not be fully provided for 1 equipment purchased with Federal funds during the current year. Cause - Administrative oversight and insufficient internal controls. Effect or Potential Effect – The University was not in compliance with equipment management requirements. Questioned Costs – None. Context – Although the University completed a physical inventory, formal documentation to support that a complete physical count was reconciled to the appropriate equipment records in the past 2 years could not be provided. As a result, we were unable to verify whether all differences between the physical inventory and equipment records were resolved. For 1 of 3 equipment purchased during the current year that was selected for testing, the Required Equipment Information could not be provided. Indication of Repeat Finding - No similar finding noted in the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over the physical inventory count of equipment purchased with Federal funds as well as the recordkeeping and retention of the Required Equipment Information, to ensure that supporting documentation for property records, as well as the physical inventory and required reconciliation of the count to records is maintained as required by the sections of 2 CFR 200.313 noted above. Views of Responsible Officials – The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations.