Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, 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. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster Grantor: Department of Health and Human Services and National Aeronautics and Space Administration Award Names: Biomedical Research and Research Training and Science Award Year: July 1, 2022 – June 30, 2023 Award Number: 5R01GM140457-03 and 80NSSC21K0753 Assistance Listing Numbers: 93.859 and 43.001 Pass-through entity: Not applicable Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, the College procedures include (amongst other items) obtaining a Commitment Form from the subrecipient, performing an initial risk assessment on all subrecipients, and updating that risk assessment based on the Controller Office’s judgement. The College also annually reviews the subrecipient's Uniform Guidance (“UG”) report and performs any necessary follow-up to issue a management decision, where applicable. Condition Through our testing of 4 subrecipients, we noted the following: • For all samples, we were unable to obtain sufficient evidence of the College’s annual subrecipient risk assessment. • For all samples, we were unable to obtain sufficient evidence of the College’s annual review of the audited financial statements and UG report, documentation of their review of the subrecipient’s audit report, and actions taken as a result of the findings in the report. Cause The College indicated subrecipient reviews, including the annual risk assessment and review of the UG report, were performed informally by the Principal Investigators and financial staff and not consistently documented. The College cites insufficient staffing needed for the formal documentation of the subrecipient risk assessment and monitoring procedures as the cause. Effect The lack of an annual review of subrecipient UG reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the UG. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs None identified. Recommendation We recommend the College reassess the design of its controls around subrecipient risk assessment and monitoring during the ongoing monitoring process. The College should formalize the documentation and review of its controls related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings.
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster Grantor: Department of Health and Human Services and National Aeronautics and Space Administration Award Names: Biomedical Research and Research Training and Science Award Year: July 1, 2022 – June 30, 2023 Award Number: 5R01GM140457-03 and 80NSSC21K0753 Assistance Listing Numbers: 93.859 and 43.001 Pass-through entity: Not applicable Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, the College procedures include (amongst other items) obtaining a Commitment Form from the subrecipient, performing an initial risk assessment on all subrecipients, and updating that risk assessment based on the Controller Office’s judgement. The College also annually reviews the subrecipient's Uniform Guidance (“UG”) report and performs any necessary follow-up to issue a management decision, where applicable. Condition Through our testing of 4 subrecipients, we noted the following: • For all samples, we were unable to obtain sufficient evidence of the College’s annual subrecipient risk assessment. • For all samples, we were unable to obtain sufficient evidence of the College’s annual review of the audited financial statements and UG report, documentation of their review of the subrecipient’s audit report, and actions taken as a result of the findings in the report. Cause The College indicated subrecipient reviews, including the annual risk assessment and review of the UG report, were performed informally by the Principal Investigators and financial staff and not consistently documented. The College cites insufficient staffing needed for the formal documentation of the subrecipient risk assessment and monitoring procedures as the cause. Effect The lack of an annual review of subrecipient UG reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the UG. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs None identified. Recommendation We recommend the College reassess the design of its controls around subrecipient risk assessment and monitoring during the ongoing monitoring process. The College should formalize the documentation and review of its controls related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings.
(2023-043) Title: Internal control over CNC subrecipient monitoring procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Child Nutrition Services Federal Agency: U.S. Department of Agriculture Assistance Listing Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Federal Award Identification Number: See E-93 to E-94 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332; 7 CFR 210.18; 7 CFR 225.7; U.S. Department of Agriculture Policy Memo SP 46-2015 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. The Department must conduct administrative reviews of School Food Authorities (SFAs) participating in the National School Lunch Program (NSLP) and the School Breakfast Program (SBP). These procedures must also be followed, as applicable, to conduct administrative reviews of the afterschool snacks, Special Milk Program (SMP) and the Fresh Fruit and Vegetable Program (FFVP). The Department must review sponsors to ensure compliance with Summer Food Service Program (SFSP) regulations. The Department is required to conduct a review of base year certification and benefit issuance documentation for any SFA requesting approval to participate in NSLP or SBP using U.S. Department of Agriculture (USDA) Special Provision 2, which is a provision established to reduce application burdens and simplify claim procedures. The review must occur at some point during the base year. If errors are identified as a result of the review, the Department must adjust all of the SFA’s closed claims that occurred in the current school year. Condition: The Child Nutrition Cluster (CNC) includes the NSLP, SBP, SMP for Children, SFSP and FFVP. The objectives of the programs are to provide nutritious meals to eligible children in schools and summer food programs; to foster healthy eating habits by providing fresh fruits and vegetables to children attending elementary schools; and to encourage consumption of nutritious agriculture commodities. The Department of Education (DOE) is responsible for the administration of child nutrition programs for the State. DOE partners with local SFAs to provide benefits to school-aged children. DOE has assigned subrecipient monitoring responsibilities, which include administrative reviews and other reviews as needed, to the Child Nutrition Services (CNS) division. Administrative reviews of all SFAs are required at least once every five years. CNS utilizes a spreadsheet to track and facilitate the reviews and a USDA questionnaire to document the completion of the review. CNS is required to retain documentation to support all elements of the administrative reviews and to demonstrate the SFA’s compliance with the program. The Office of the State Auditor (OSA) tested 15 NSLP and SFSP administrative reviews and found: • the review tracking spreadsheet was not fully completed for two reviews; • questionnaires were not fully completed for three reviews; and • information on the USDA questionnaire was inaccurate for four reviews. Therefore, documentation does not support that all required areas were reviewed in accordance with Federal regulations; however, the Final Review Report issued and corrective action taken suggests that a full onsite review was completed. OSA selected a non-statistical random sample. In addition, CNS must perform reviews for all SFAs that have applied to participate in USDA Special Provision 2. These base reviews provide the required information necessary to determine the level of claims the SFA may submit in the subsequent year. After completion of the base year review, a letter detailing the results, including any adjustments to previously submitted claims, is provided to the SFA. The SFA is required to adjust claims and enrollment data through the claim revision process and CNS is responsible for verifying that the appropriate revisions have been completed. In fiscal year 2023, CNS identified 99 SFAs that required a base year review. OSA tested 15 base year reviews and identified nine SFAs that did not properly revise claims, and CNS did not verify that the appropriate revisions had been completed. OSA selected a non-statistical random sample. Context: In fiscal year 2023, CNC expenditures totaled approximately $79 million, of which approximately $69 million was provided to 247 SFAs. Cause: • Lack of policies and procedures • Lack of supervisory oversight Effect: • Noncompliance with Federal regulations • Subrecipients may not be complying with Federal statues, regulations, or the terms and conditions of the subaward. • Potential questioned costs and disallowances. Base year reviews provide authorization for the level of allowable claims the SFA can claim in subsequent periods. Without a base year review and necessary revisions, SFAs could be underclaiming or overclaiming costs. Recommendation: We recommend that the Department implement policies and procedures and increase oversight to ensure that: • reviews are completed as required and supporting documentation is retained; • SFAs revise claims appropriately after a base year review; and • CNS verifies that claim adjustments occur as necessary. Corrective Action Plan: See F-22 Management’s Response: The Department agrees with this finding. Policies and procedures will be implemented, and training will be provided to ensure that reviews are completed and documentation is retained, SFA claims are revised appropriately, and verifications of claim adjustments occur as necessary. Contact: Adriane Ackroyd, Assistant Director Child Nutrition, DOE, 207-592-1722 (State Number: 23-1203-03)
(2023-043) Title: Internal control over CNC subrecipient monitoring procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Child Nutrition Services Federal Agency: U.S. Department of Agriculture Assistance Listing Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Federal Award Identification Number: See E-93 to E-94 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332; 7 CFR 210.18; 7 CFR 225.7; U.S. Department of Agriculture Policy Memo SP 46-2015 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. The Department must conduct administrative reviews of School Food Authorities (SFAs) participating in the National School Lunch Program (NSLP) and the School Breakfast Program (SBP). These procedures must also be followed, as applicable, to conduct administrative reviews of the afterschool snacks, Special Milk Program (SMP) and the Fresh Fruit and Vegetable Program (FFVP). The Department must review sponsors to ensure compliance with Summer Food Service Program (SFSP) regulations. The Department is required to conduct a review of base year certification and benefit issuance documentation for any SFA requesting approval to participate in NSLP or SBP using U.S. Department of Agriculture (USDA) Special Provision 2, which is a provision established to reduce application burdens and simplify claim procedures. The review must occur at some point during the base year. If errors are identified as a result of the review, the Department must adjust all of the SFA’s closed claims that occurred in the current school year. Condition: The Child Nutrition Cluster (CNC) includes the NSLP, SBP, SMP for Children, SFSP and FFVP. The objectives of the programs are to provide nutritious meals to eligible children in schools and summer food programs; to foster healthy eating habits by providing fresh fruits and vegetables to children attending elementary schools; and to encourage consumption of nutritious agriculture commodities. The Department of Education (DOE) is responsible for the administration of child nutrition programs for the State. DOE partners with local SFAs to provide benefits to school-aged children. DOE has assigned subrecipient monitoring responsibilities, which include administrative reviews and other reviews as needed, to the Child Nutrition Services (CNS) division. Administrative reviews of all SFAs are required at least once every five years. CNS utilizes a spreadsheet to track and facilitate the reviews and a USDA questionnaire to document the completion of the review. CNS is required to retain documentation to support all elements of the administrative reviews and to demonstrate the SFA’s compliance with the program. The Office of the State Auditor (OSA) tested 15 NSLP and SFSP administrative reviews and found: • the review tracking spreadsheet was not fully completed for two reviews; • questionnaires were not fully completed for three reviews; and • information on the USDA questionnaire was inaccurate for four reviews. Therefore, documentation does not support that all required areas were reviewed in accordance with Federal regulations; however, the Final Review Report issued and corrective action taken suggests that a full onsite review was completed. OSA selected a non-statistical random sample. In addition, CNS must perform reviews for all SFAs that have applied to participate in USDA Special Provision 2. These base reviews provide the required information necessary to determine the level of claims the SFA may submit in the subsequent year. After completion of the base year review, a letter detailing the results, including any adjustments to previously submitted claims, is provided to the SFA. The SFA is required to adjust claims and enrollment data through the claim revision process and CNS is responsible for verifying that the appropriate revisions have been completed. In fiscal year 2023, CNS identified 99 SFAs that required a base year review. OSA tested 15 base year reviews and identified nine SFAs that did not properly revise claims, and CNS did not verify that the appropriate revisions had been completed. OSA selected a non-statistical random sample. Context: In fiscal year 2023, CNC expenditures totaled approximately $79 million, of which approximately $69 million was provided to 247 SFAs. Cause: • Lack of policies and procedures • Lack of supervisory oversight Effect: • Noncompliance with Federal regulations • Subrecipients may not be complying with Federal statues, regulations, or the terms and conditions of the subaward. • Potential questioned costs and disallowances. Base year reviews provide authorization for the level of allowable claims the SFA can claim in subsequent periods. Without a base year review and necessary revisions, SFAs could be underclaiming or overclaiming costs. Recommendation: We recommend that the Department implement policies and procedures and increase oversight to ensure that: • reviews are completed as required and supporting documentation is retained; • SFAs revise claims appropriately after a base year review; and • CNS verifies that claim adjustments occur as necessary. Corrective Action Plan: See F-22 Management’s Response: The Department agrees with this finding. Policies and procedures will be implemented, and training will be provided to ensure that reviews are completed and documentation is retained, SFA claims are revised appropriately, and verifications of claim adjustments occur as necessary. Contact: Adriane Ackroyd, Assistant Director Child Nutrition, DOE, 207-592-1722 (State Number: 23-1203-03)
(2023-043) Title: Internal control over CNC subrecipient monitoring procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Child Nutrition Services Federal Agency: U.S. Department of Agriculture Assistance Listing Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Federal Award Identification Number: See E-93 to E-94 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332; 7 CFR 210.18; 7 CFR 225.7; U.S. Department of Agriculture Policy Memo SP 46-2015 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. The Department must conduct administrative reviews of School Food Authorities (SFAs) participating in the National School Lunch Program (NSLP) and the School Breakfast Program (SBP). These procedures must also be followed, as applicable, to conduct administrative reviews of the afterschool snacks, Special Milk Program (SMP) and the Fresh Fruit and Vegetable Program (FFVP). The Department must review sponsors to ensure compliance with Summer Food Service Program (SFSP) regulations. The Department is required to conduct a review of base year certification and benefit issuance documentation for any SFA requesting approval to participate in NSLP or SBP using U.S. Department of Agriculture (USDA) Special Provision 2, which is a provision established to reduce application burdens and simplify claim procedures. The review must occur at some point during the base year. If errors are identified as a result of the review, the Department must adjust all of the SFA’s closed claims that occurred in the current school year. Condition: The Child Nutrition Cluster (CNC) includes the NSLP, SBP, SMP for Children, SFSP and FFVP. The objectives of the programs are to provide nutritious meals to eligible children in schools and summer food programs; to foster healthy eating habits by providing fresh fruits and vegetables to children attending elementary schools; and to encourage consumption of nutritious agriculture commodities. The Department of Education (DOE) is responsible for the administration of child nutrition programs for the State. DOE partners with local SFAs to provide benefits to school-aged children. DOE has assigned subrecipient monitoring responsibilities, which include administrative reviews and other reviews as needed, to the Child Nutrition Services (CNS) division. Administrative reviews of all SFAs are required at least once every five years. CNS utilizes a spreadsheet to track and facilitate the reviews and a USDA questionnaire to document the completion of the review. CNS is required to retain documentation to support all elements of the administrative reviews and to demonstrate the SFA’s compliance with the program. The Office of the State Auditor (OSA) tested 15 NSLP and SFSP administrative reviews and found: • the review tracking spreadsheet was not fully completed for two reviews; • questionnaires were not fully completed for three reviews; and • information on the USDA questionnaire was inaccurate for four reviews. Therefore, documentation does not support that all required areas were reviewed in accordance with Federal regulations; however, the Final Review Report issued and corrective action taken suggests that a full onsite review was completed. OSA selected a non-statistical random sample. In addition, CNS must perform reviews for all SFAs that have applied to participate in USDA Special Provision 2. These base reviews provide the required information necessary to determine the level of claims the SFA may submit in the subsequent year. After completion of the base year review, a letter detailing the results, including any adjustments to previously submitted claims, is provided to the SFA. The SFA is required to adjust claims and enrollment data through the claim revision process and CNS is responsible for verifying that the appropriate revisions have been completed. In fiscal year 2023, CNS identified 99 SFAs that required a base year review. OSA tested 15 base year reviews and identified nine SFAs that did not properly revise claims, and CNS did not verify that the appropriate revisions had been completed. OSA selected a non-statistical random sample. Context: In fiscal year 2023, CNC expenditures totaled approximately $79 million, of which approximately $69 million was provided to 247 SFAs. Cause: • Lack of policies and procedures • Lack of supervisory oversight Effect: • Noncompliance with Federal regulations • Subrecipients may not be complying with Federal statues, regulations, or the terms and conditions of the subaward. • Potential questioned costs and disallowances. Base year reviews provide authorization for the level of allowable claims the SFA can claim in subsequent periods. Without a base year review and necessary revisions, SFAs could be underclaiming or overclaiming costs. Recommendation: We recommend that the Department implement policies and procedures and increase oversight to ensure that: • reviews are completed as required and supporting documentation is retained; • SFAs revise claims appropriately after a base year review; and • CNS verifies that claim adjustments occur as necessary. Corrective Action Plan: See F-22 Management’s Response: The Department agrees with this finding. Policies and procedures will be implemented, and training will be provided to ensure that reviews are completed and documentation is retained, SFA claims are revised appropriately, and verifications of claim adjustments occur as necessary. Contact: Adriane Ackroyd, Assistant Director Child Nutrition, DOE, 207-592-1722 (State Number: 23-1203-03)
(2023-047) Title: Internal control over CACFP subrecipient monitoring procedures needs improvement Prior Year Findings: See schedule of Findings and Questioned Costs for chart/table State Department: Education State Bureau: Child Nutrition Services Federal Agency: U.S Department of Agriculture Assistance Listing Title: Child and Adult Care Food Program (CACFP) Assistance Listing Number: 10.558 Federal Award Identification Number: See E-93 to E-94 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332; 7 CFR 226.6 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department must: • evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring procedures. • verify that the subrecipient is audited as required when a subrecipient’s Federal award expenditures are expected to equal or exceed $750,000 during the fiscal year. • monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. 7 CFR 226.6 outlines specific scheduling requirements for monitoring by the Department including: • reviewing at least 33.3 percent of all institutions annually; • reviewing Sponsoring Organizations (SOs) that operate 1 to 100 facilities at least once every three years; and • reviewing SOs that operate more than 100 facilities, which conduct activities other than the Child and Adult Care Food Program (CACFP), that have been identified during a recent review as having serious management problems, or that are at risk of having serious management problems, at least once every two years. Condition: CACFP provides nutritious foods that contribute to the wellness, healthy growth, and development of eligible children and adults receiving care in day care centers, day care homes, and at-risk after school snack programs. Child Nutrition Services (CNS) is responsible for monitoring approximately 104 subrecipients that administer these services. The level of monitoring required by Federal regulations must be determined using a risk-based approach. Subrecipient risk evaluation procedures should include considerations of: • the subrecipient’s experience with the program, • the results of subrecipient audits, • changes in personnel or systems, and • the extent of Federal awarding agency monitoring procedures. Subrecipient risk evaluation The level of subrecipient monitoring procedures performed in fiscal year 2023 were based on CACFP regulations rather than a risk-based approach as required by Federal regulations. In response to this repeat finding, CNS developed a documented risk evaluation process which will be utilized to plan monitoring activities for fiscal year 2024. Subrecipient audit verification CNS identified 22 non-profit and for-profit subrecipients which expended over $750,000 in fiscal year 2023, therefore requiring verification of subrecipient audits. The Office of the State Auditor (OSA) identified one additional subrecipient that required a Single Audit that CNS did not identify. OSA was able to confirm that the subrecipient did have a Single Audit as required. Additionally, CNS did not obtain documentation from subrecipients to support extensions for audits that had not been completed. Subrecipient monitoring As noted above, in accordance with CACFP regulations, CNS utilizes a three-year administrative review cycle to monitor subrecipients. Reviews are required to be completed by the end of the cycle ending September 30 of each fiscal year and include both on-site and desk reviews. CNS schedules and conducts the reviews, holds exit meetings, provides the subrecipient with a report, and if applicable, requires the subrecipient to document corrective action plans, which CNS follows up on as needed. Once corrective action is completed, CNS issues a final review closeout letter. OSA tested a sample of eight scheduled administrative reviews that were required for completion in fiscal year 2023 and identified two reviews that were started within the cycle but not yet completed. The on-site reviews were conducted April 4, 2023, and May 23, 2023, respectively, but the desk portion of the reviews had not been completed as of February 2024; therefore, the exit meeting and reports have not been issued. OSA selected a non-statistical random sample. Context: In fiscal year 2023, CACFP expenditures totaled $9.8 million, of which $9.7 million in CACFP funds was provided to 104 subrecipients. Cause: • Lack of adequate policies and procedures • Lack of staff resources available to complete the administrative reviews timely Effect: • Noncompliance with Federal regulations • Subrecipients that are deemed higher risk may not be monitored on a more frequent basis. Conversely, subrecipients that are deemed lower risk may not be monitored on a less frequent basis, which would free resources and time to dedicate towards other higher risk subrecipients. • Subrecipients may not be complying with Federal statutes, regulations, or the terms and conditions of the subaward. Recommendation: We recommend that the Department: • utilize and evaluate the effectiveness of the newly established risk evaluation process; • enhance policies and procedures to ensure that audit reports for all subrecipients receiving over $750,000 in Federal awards requiring audits are properly identified, tracked, received, and reviewed; • enhance documentation to support reasons for late or missing audit reports; and • implement a process to ensure that the backlog of reviews is completed and allocate resources to ensure all portions of the administrative reviews are fully completed. Corrective Action Plan: See F-23 Management’s Response: The Department agrees with this finding. The CACFP Team in Child Nutrition has made significant improvements since the prior year single audit. This finding is due to the timing of the single audit and the time it takes to implement corrective action, the Department responding to a Federal Audit, the withdrawal of a subrecipient, and the process to hire additional staff. Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880 (State Number: 23-1115-01)
(2023-043) Title: Internal control over CNC subrecipient monitoring procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Child Nutrition Services Federal Agency: U.S. Department of Agriculture Assistance Listing Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Federal Award Identification Number: See E-93 to E-94 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332; 7 CFR 210.18; 7 CFR 225.7; U.S. Department of Agriculture Policy Memo SP 46-2015 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. The Department must conduct administrative reviews of School Food Authorities (SFAs) participating in the National School Lunch Program (NSLP) and the School Breakfast Program (SBP). These procedures must also be followed, as applicable, to conduct administrative reviews of the afterschool snacks, Special Milk Program (SMP) and the Fresh Fruit and Vegetable Program (FFVP). The Department must review sponsors to ensure compliance with Summer Food Service Program (SFSP) regulations. The Department is required to conduct a review of base year certification and benefit issuance documentation for any SFA requesting approval to participate in NSLP or SBP using U.S. Department of Agriculture (USDA) Special Provision 2, which is a provision established to reduce application burdens and simplify claim procedures. The review must occur at some point during the base year. If errors are identified as a result of the review, the Department must adjust all of the SFA’s closed claims that occurred in the current school year. Condition: The Child Nutrition Cluster (CNC) includes the NSLP, SBP, SMP for Children, SFSP and FFVP. The objectives of the programs are to provide nutritious meals to eligible children in schools and summer food programs; to foster healthy eating habits by providing fresh fruits and vegetables to children attending elementary schools; and to encourage consumption of nutritious agriculture commodities. The Department of Education (DOE) is responsible for the administration of child nutrition programs for the State. DOE partners with local SFAs to provide benefits to school-aged children. DOE has assigned subrecipient monitoring responsibilities, which include administrative reviews and other reviews as needed, to the Child Nutrition Services (CNS) division. Administrative reviews of all SFAs are required at least once every five years. CNS utilizes a spreadsheet to track and facilitate the reviews and a USDA questionnaire to document the completion of the review. CNS is required to retain documentation to support all elements of the administrative reviews and to demonstrate the SFA’s compliance with the program. The Office of the State Auditor (OSA) tested 15 NSLP and SFSP administrative reviews and found: • the review tracking spreadsheet was not fully completed for two reviews; • questionnaires were not fully completed for three reviews; and • information on the USDA questionnaire was inaccurate for four reviews. Therefore, documentation does not support that all required areas were reviewed in accordance with Federal regulations; however, the Final Review Report issued and corrective action taken suggests that a full onsite review was completed. OSA selected a non-statistical random sample. In addition, CNS must perform reviews for all SFAs that have applied to participate in USDA Special Provision 2. These base reviews provide the required information necessary to determine the level of claims the SFA may submit in the subsequent year. After completion of the base year review, a letter detailing the results, including any adjustments to previously submitted claims, is provided to the SFA. The SFA is required to adjust claims and enrollment data through the claim revision process and CNS is responsible for verifying that the appropriate revisions have been completed. In fiscal year 2023, CNS identified 99 SFAs that required a base year review. OSA tested 15 base year reviews and identified nine SFAs that did not properly revise claims, and CNS did not verify that the appropriate revisions had been completed. OSA selected a non-statistical random sample. Context: In fiscal year 2023, CNC expenditures totaled approximately $79 million, of which approximately $69 million was provided to 247 SFAs. Cause: • Lack of policies and procedures • Lack of supervisory oversight Effect: • Noncompliance with Federal regulations • Subrecipients may not be complying with Federal statues, regulations, or the terms and conditions of the subaward. • Potential questioned costs and disallowances. Base year reviews provide authorization for the level of allowable claims the SFA can claim in subsequent periods. Without a base year review and necessary revisions, SFAs could be underclaiming or overclaiming costs. Recommendation: We recommend that the Department implement policies and procedures and increase oversight to ensure that: • reviews are completed as required and supporting documentation is retained; • SFAs revise claims appropriately after a base year review; and • CNS verifies that claim adjustments occur as necessary. Corrective Action Plan: See F-22 Management’s Response: The Department agrees with this finding. Policies and procedures will be implemented, and training will be provided to ensure that reviews are completed and documentation is retained, SFA claims are revised appropriately, and verifications of claim adjustments occur as necessary. Contact: Adriane Ackroyd, Assistant Director Child Nutrition, DOE, 207-592-1722 (State Number: 23-1203-03)
(2023-043) Title: Internal control over CNC subrecipient monitoring procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Child Nutrition Services Federal Agency: U.S. Department of Agriculture Assistance Listing Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Federal Award Identification Number: See E-93 to E-94 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332; 7 CFR 210.18; 7 CFR 225.7; U.S. Department of Agriculture Policy Memo SP 46-2015 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. The Department must conduct administrative reviews of School Food Authorities (SFAs) participating in the National School Lunch Program (NSLP) and the School Breakfast Program (SBP). These procedures must also be followed, as applicable, to conduct administrative reviews of the afterschool snacks, Special Milk Program (SMP) and the Fresh Fruit and Vegetable Program (FFVP). The Department must review sponsors to ensure compliance with Summer Food Service Program (SFSP) regulations. The Department is required to conduct a review of base year certification and benefit issuance documentation for any SFA requesting approval to participate in NSLP or SBP using U.S. Department of Agriculture (USDA) Special Provision 2, which is a provision established to reduce application burdens and simplify claim procedures. The review must occur at some point during the base year. If errors are identified as a result of the review, the Department must adjust all of the SFA’s closed claims that occurred in the current school year. Condition: The Child Nutrition Cluster (CNC) includes the NSLP, SBP, SMP for Children, SFSP and FFVP. The objectives of the programs are to provide nutritious meals to eligible children in schools and summer food programs; to foster healthy eating habits by providing fresh fruits and vegetables to children attending elementary schools; and to encourage consumption of nutritious agriculture commodities. The Department of Education (DOE) is responsible for the administration of child nutrition programs for the State. DOE partners with local SFAs to provide benefits to school-aged children. DOE has assigned subrecipient monitoring responsibilities, which include administrative reviews and other reviews as needed, to the Child Nutrition Services (CNS) division. Administrative reviews of all SFAs are required at least once every five years. CNS utilizes a spreadsheet to track and facilitate the reviews and a USDA questionnaire to document the completion of the review. CNS is required to retain documentation to support all elements of the administrative reviews and to demonstrate the SFA’s compliance with the program. The Office of the State Auditor (OSA) tested 15 NSLP and SFSP administrative reviews and found: • the review tracking spreadsheet was not fully completed for two reviews; • questionnaires were not fully completed for three reviews; and • information on the USDA questionnaire was inaccurate for four reviews. Therefore, documentation does not support that all required areas were reviewed in accordance with Federal regulations; however, the Final Review Report issued and corrective action taken suggests that a full onsite review was completed. OSA selected a non-statistical random sample. In addition, CNS must perform reviews for all SFAs that have applied to participate in USDA Special Provision 2. These base reviews provide the required information necessary to determine the level of claims the SFA may submit in the subsequent year. After completion of the base year review, a letter detailing the results, including any adjustments to previously submitted claims, is provided to the SFA. The SFA is required to adjust claims and enrollment data through the claim revision process and CNS is responsible for verifying that the appropriate revisions have been completed. In fiscal year 2023, CNS identified 99 SFAs that required a base year review. OSA tested 15 base year reviews and identified nine SFAs that did not properly revise claims, and CNS did not verify that the appropriate revisions had been completed. OSA selected a non-statistical random sample. Context: In fiscal year 2023, CNC expenditures totaled approximately $79 million, of which approximately $69 million was provided to 247 SFAs. Cause: • Lack of policies and procedures • Lack of supervisory oversight Effect: • Noncompliance with Federal regulations • Subrecipients may not be complying with Federal statues, regulations, or the terms and conditions of the subaward. • Potential questioned costs and disallowances. Base year reviews provide authorization for the level of allowable claims the SFA can claim in subsequent periods. Without a base year review and necessary revisions, SFAs could be underclaiming or overclaiming costs. Recommendation: We recommend that the Department implement policies and procedures and increase oversight to ensure that: • reviews are completed as required and supporting documentation is retained; • SFAs revise claims appropriately after a base year review; and • CNS verifies that claim adjustments occur as necessary. Corrective Action Plan: See F-22 Management’s Response: The Department agrees with this finding. Policies and procedures will be implemented, and training will be provided to ensure that reviews are completed and documentation is retained, SFA claims are revised appropriately, and verifications of claim adjustments occur as necessary. Contact: Adriane Ackroyd, Assistant Director Child Nutrition, DOE, 207-592-1722 (State Number: 23-1203-03)