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.
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.
2024-007: U.S. Department of Homeland Security Pass-through North Lake Tahoe Fire Protection District Assistance to Firefighters Grant, 97.044 Equipment and Real Property Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards under assistance listing 97.044 on the Schedule of Expenditures of Federal Awards Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.313 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 federal award identification number), who holds title, 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. Condition: Property records did not originally include the title, acquisition date, percentage of federal participation, and condition of the equipment. Cause: Tahoe Douglas Fire Protection District (the District) did not have adequate internal controls to ensure property records track all applicable information on equipment purchased with federal funds. Effect: Incomplete information was maintained for federal equipment. Questioned Costs: None Context/Sampling: A nonstatistical sample of 9 out of 57 equipment was selected for testing. None of the equipment tested included all required information. Repeat Finding from Prior Year: No Recommendation: We recommend the District enhance internal controls to ensure property records are appropriately maintained. Views of Responsible Officials: Tahoe Douglas Fire Protection District agrees with this finding.
2024-001. Equipment and Real Property Management United States of Department of Education, Passed Through New York State, Department of Education: Education Stabilization Fund COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan - Elementary and Secondary School Emergency Relief ALN: 84.425U Criteria: Education Stabilization Fund (ESF) grant awards authorized under the federal Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act and American Rescue Plan Act of 2021 (ARP) may be used for equipment purchases and capital expenditures, consistent with federal regulations 2 CFR §200.313 and 2 CFR §200.439. In accordance with 2 CFR §200.313, non-federal entities receiving federal awards are required to have procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a federal award, until disposition takes place. This includes maintaining property records 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 (FAIN), and who holds title. In addition, it requires non-federal entities to track the acquisition date and cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. A physical inventory of the property acquired with federal awards must also be taken and the results reconciled with the property inventory records at least once every two years. Condition: The District did not include COVID grants-funded capital improvements in its capital assets inventory records. Cause: Insufficient internal controls over the tracking and reporting of federally-funded capital improvements. The District recorded expenditures for CRRSA and ARP grants-funded capital improvements and upgrades to its facilities and ventilation systems as contractual/purchased services in the special aid fund based on instructions from the pass-through entity instead of in the capital projects fund. As a result, District personnel compiling annual capital additions information did not identify the COVID grants-funded capital improvements as capital assets that should be added to the capital assets inventory listing. Effect: Failure to include capital improvements acquired with Federal awards in the District’s capital assets inventory records affects its financial reporting in conformity with Generally Accepted Accounting Principles (GAAP) and could lead to improper or non-compliant procedures for assets inventory management, and the subsequent disposal of those capital assets. Questioned Costs: None reported. Context: The District uses specific expenditure codes in its special aid fund to identify and track various categories of expenditures incurred that are reimbursable under various Federal awards, including the ESSER grant awards under the CRRSA Act and ARP. Based on instructions from the pass-through entity, the New York State Education Department (NYSED), the District included eligible capital improvement costs in its CRRSA ESSER 2 and ARP ESSER 3 budget applications as purchased services, which were approved by the NYSED, and recorded the expenditures in its special aid fund’s contractual expenditures object code (.400 code). When District personnel compiled the listing of capital improvements additions for the fiscal year to perform the annual update of the capital assets inventory record, they reviewed and included capital costs from the District’s capital projects fund, but did not review or identify the costs of the various capital improvements that were recorded in the special aid fund’s .400 contractual expenditures code. Identification of a Repeat Finding: This is not a repeat finding from the immediately prior audit. Recommendation: The District should review and revise its existing procedures for compiling annual capital assets additions information to ensure capital expenditures purchased with Federal awards that meet the District’s capitalization threshold are considered and evaluated for inclusion in the District’s annual capital assets inventory records as appropriate. Views of Responsible Officials of Auditee: The District acknowledges but does not fully agree with this finding. federally-funded expenditures were recorded in the Special Aid Fund as purchased services, both on the FS-10 budgets and the purchase orders for portion of the capital improvement projects the PO’s were issued against. These payments are partially payments to contractors for wages, labor, materials, and other items, not necessarily equipment. The methods of financing for all these costs are reported on the State SA-139 Building Project Data Forms as partially funded by grants from ARPA & ESSER and annual district appropriation budget; hence, in the District’s annual capital asset inventory report, they will eventually be reconciled with the final building project cost report and will be added and tracked as part of the whole capital improvement projects.
2024-001. Equipment and Real Property Management United States of Department of Education, Passed Through New York State, Department of Education: Education Stabilization Fund COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan - Elementary and Secondary School Emergency Relief ALN: 84.425U Criteria: Education Stabilization Fund (ESF) grant awards authorized under the federal Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act and American Rescue Plan Act of 2021 (ARP) may be used for equipment purchases and capital expenditures, consistent with federal regulations 2 CFR §200.313 and 2 CFR §200.439. In accordance with 2 CFR §200.313, non-federal entities receiving federal awards are required to have procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a federal award, until disposition takes place. This includes maintaining property records 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 (FAIN), and who holds title. In addition, it requires non-federal entities to track the acquisition date and cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. A physical inventory of the property acquired with federal awards must also be taken and the results reconciled with the property inventory records at least once every two years. Condition: The District did not include COVID grants-funded capital improvements in its capital assets inventory records. Cause: Insufficient internal controls over the tracking and reporting of federally-funded capital improvements. The District recorded expenditures for CRRSA and ARP grants-funded capital improvements and upgrades to its facilities and ventilation systems as contractual/purchased services in the special aid fund based on instructions from the pass-through entity instead of in the capital projects fund. As a result, District personnel compiling annual capital additions information did not identify the COVID grants-funded capital improvements as capital assets that should be added to the capital assets inventory listing. Effect: Failure to include capital improvements acquired with Federal awards in the District’s capital assets inventory records affects its financial reporting in conformity with Generally Accepted Accounting Principles (GAAP) and could lead to improper or non-compliant procedures for assets inventory management, and the subsequent disposal of those capital assets. Questioned Costs: None reported. Context: The District uses specific expenditure codes in its special aid fund to identify and track various categories of expenditures incurred that are reimbursable under various Federal awards, including the ESSER grant awards under the CRRSA Act and ARP. Based on instructions from the pass-through entity, the New York State Education Department (NYSED), the District included eligible capital improvement costs in its CRRSA ESSER 2 and ARP ESSER 3 budget applications as purchased services, which were approved by the NYSED, and recorded the expenditures in its special aid fund’s contractual expenditures object code (.400 code). When District personnel compiled the listing of capital improvements additions for the fiscal year to perform the annual update of the capital assets inventory record, they reviewed and included capital costs from the District’s capital projects fund, but did not review or identify the costs of the various capital improvements that were recorded in the special aid fund’s .400 contractual expenditures code. Identification of a Repeat Finding: This is not a repeat finding from the immediately prior audit. Recommendation: The District should review and revise its existing procedures for compiling annual capital assets additions information to ensure capital expenditures purchased with Federal awards that meet the District’s capitalization threshold are considered and evaluated for inclusion in the District’s annual capital assets inventory records as appropriate. Views of Responsible Officials of Auditee: The District acknowledges but does not fully agree with this finding. federally-funded expenditures were recorded in the Special Aid Fund as purchased services, both on the FS-10 budgets and the purchase orders for portion of the capital improvement projects the PO’s were issued against. These payments are partially payments to contractors for wages, labor, materials, and other items, not necessarily equipment. The methods of financing for all these costs are reported on the State SA-139 Building Project Data Forms as partially funded by grants from ARPA & ESSER and annual district appropriation budget; hence, in the District’s annual capital asset inventory report, they will eventually be reconciled with the final building project cost report and will be added and tracked as part of the whole capital improvement projects.
2024-001 U.S. Department of Education, Charter Schools (CSP) Assistance Listing Number 84.282 Equipment Management Significant Deficiency in Internal Control over Compliance Criteria: Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the 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 (2 CFR section 200.313(d)(1)). Condition: The School does not appear to be tracking all of the elements required by the federal government when purchasing equipment with federal funds. Cause: While the School does track the property purchased with federal funds, they do not appear have formal policies in place for ensuring the completeness of property records. Effect: The School does not comply with requirements to maintain certain elements as required by the federal government when purchasing equipment with federal funds. Questioned costs: None reported. Context: Out of our sample of 3 equipment purchases, we noted that the School records did not contain all of the elements required by the Federal government. Nonstatistical sampling was used. Repeat Finding From Prior Year: No Recommendation: We recommend that management design procedures to ensure that all of the required elements are maintained in the property records for any equipment purchased with federal funds. Views of Responsible Officials: We agree with the finding.
FINDING 2024-002 – EQUIPMENT AND REAL PROPERTY MANAGEMENT Significant Deficiency Federal Programs: Education Stabilization Fund – Assistance Listing Number 84.425 Repeat Finding: This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2023-002. Criteria 2 CFR 200.313(d) contains equipment management requirements which dictate property records entities must maintain and the need for procedures to adequately safeguard and maintain assets acquired with federal funding. Condition The Organization did not retain in their accounting records all the required information. Specifically, the federal award identification number, holder of the title, use, and condition were not listed. The federal participation was assumed based on allocations between fund codes in the general ledger. Additionally, sufficient and appropriate documentation did not exist to support a physical inventory had been completed for all assets once in the last two years. Cause and Effect As described in 2024-001, the Organization has not established a formal process related to federal awards to identify all key compliance requirements and changes in compliance requirements, evaluate risks of noncompliance with these requirements, and respond to such risks of noncompliance through establishing or changing processes and internal controls. Additionally, certain individuals, within a department, responsible for the use of federal funds or maintenance and safeguard of assets acquired with federal funds lacked knowledge of the compliance requirements pertaining to the use of the funds or the maintenance and safeguard of the acquired assets. As a result, adequate documentation was not maintained for equipment acquired with federal funds or to support the performance of a physical inventory occurring within the required time period. Recommendation We recommend the Organization develop a system of internal controls aligned with the applicable compliance requirements to properly track equipment acquisitions in the accounting records and to ensure a physical inventory is appropriately documented when completed. Views of Responsible Officials and Planned Corrective Actions The Organization’s Corrective Action Plan is included on pages 42 through 44.
2024-007 (2023-012) – EQUIPMENT AND REAL PROPERTY MANAGEMENT Type of Finding: (E) Material Weakness in Internal Control Over Compliance of Federal Awards and (G) Instance of Non-compliance related to Federal Awards Funding Agency: U.S. Department of Transportation Title: Airport Improvement Program AL #: 20.106 Award #: 3-35-0039-031-2024, 3-35-0039-027-2022, 3-35-0039-028-2022, 3-35-0039-029-2023 Award Period: May 1, 2024 – January 1, 2025, December 13, 2021 – December 13, 2025, June 24, 2022 – June 24, 2026, July 3, 2023 – July 7, 2027 Questioned Costs: None Statement of Condition The County was not able to provide a complete and accurate equipment listing tracking items purchased with federal funding nor did the County conduct a physical inventory identifying federal assets. Management’s Progress Toward Prior Year Corrective Action Plan: There was no progress made in the year ended June 30, 2024. Criteria Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.313(d)(1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results reconciled with the property records at least once every 2 years. Cause The County is not following policy and procedures to ensure that equipment purchased with federal funds is maintained and tracked and the County performing a physical inventory at a minimum of every two years. Effect The County could dispose of or lose federally funded equipment without following federal guidelines. Recommendation The auditor recommends the County enhance the design of its control activities and policies and procedures should be developed to ensure physical inventories are taken at least once every two years and that the County creates a tool to assist in tracking and maintaining equipment purchased with federal funds.
2024-007 (2023-012) – EQUIPMENT AND REAL PROPERTY MANAGEMENT Type of Finding: (E) Material Weakness in Internal Control Over Compliance of Federal Awards and (G) Instance of Non-compliance related to Federal Awards Funding Agency: U.S. Department of Transportation Title: Airport Improvement Program AL #: 20.106 Award #: 3-35-0039-031-2024, 3-35-0039-027-2022, 3-35-0039-028-2022, 3-35-0039-029-2023 Award Period: May 1, 2024 – January 1, 2025, December 13, 2021 – December 13, 2025, June 24, 2022 – June 24, 2026, July 3, 2023 – July 7, 2027 Questioned Costs: None Statement of Condition The County was not able to provide a complete and accurate equipment listing tracking items purchased with federal funding nor did the County conduct a physical inventory identifying federal assets. Management’s Progress Toward Prior Year Corrective Action Plan: There was no progress made in the year ended June 30, 2024. Criteria Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.313(d)(1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results reconciled with the property records at least once every 2 years. Cause The County is not following policy and procedures to ensure that equipment purchased with federal funds is maintained and tracked and the County performing a physical inventory at a minimum of every two years. Effect The County could dispose of or lose federally funded equipment without following federal guidelines. Recommendation The auditor recommends the County enhance the design of its control activities and policies and procedures should be developed to ensure physical inventories are taken at least once every two years and that the County creates a tool to assist in tracking and maintaining equipment purchased with federal funds.
2024-007 (2023-012) – EQUIPMENT AND REAL PROPERTY MANAGEMENT Type of Finding: (E) Material Weakness in Internal Control Over Compliance of Federal Awards and (G) Instance of Non-compliance related to Federal Awards Funding Agency: U.S. Department of Transportation Title: Airport Improvement Program AL #: 20.106 Award #: 3-35-0039-031-2024, 3-35-0039-027-2022, 3-35-0039-028-2022, 3-35-0039-029-2023 Award Period: May 1, 2024 – January 1, 2025, December 13, 2021 – December 13, 2025, June 24, 2022 – June 24, 2026, July 3, 2023 – July 7, 2027 Questioned Costs: None Statement of Condition The County was not able to provide a complete and accurate equipment listing tracking items purchased with federal funding nor did the County conduct a physical inventory identifying federal assets. Management’s Progress Toward Prior Year Corrective Action Plan: There was no progress made in the year ended June 30, 2024. Criteria Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.313(d)(1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results reconciled with the property records at least once every 2 years. Cause The County is not following policy and procedures to ensure that equipment purchased with federal funds is maintained and tracked and the County performing a physical inventory at a minimum of every two years. Effect The County could dispose of or lose federally funded equipment without following federal guidelines. Recommendation The auditor recommends the County enhance the design of its control activities and policies and procedures should be developed to ensure physical inventories are taken at least once every two years and that the County creates a tool to assist in tracking and maintaining equipment purchased with federal funds.