Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency Criteria In accordance with 2 CFR 200.332(d), all pass-through entities 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. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and programmatic (performance and special reports) required by the pass-through entity (PTE). ? 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. ? 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. ? The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. In accordance with 2 CFR 200.332(d), all pass-through entities must verify that every subrecipient is audited as required by Subpart F of 2 CFR 200.500 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. In accordance with 2 CFR 200.521(c) and (d): the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). In accordance with 2 CFR 200.501(h), since 2 CFR Part 200 does not make Subpart F applicable to for-profit subrecipients, the PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Condition, including Perspective Lehigh University passed through $3,277,289 to its subrecipients in the research and development cluster (R&D cluster), which represents approximately 10% of total R&D cluster expenditures for the year ended June 30, 2022. As a pass-through entity, Lehigh University?s Office of Research and Special Projects (ORSP) is responsible for monitoring the activities and compliance of its subrecipients. Monitoring includes reviewing the compliance audit reports from its subrecipients as they become available through the federal audit clearinghouse to ascertain the existence of non-compliance and appropriate follow-up with the subrecipient to ensure timely and appropriate corrective action is taken to remediate the finding(s). Our procedures performed determined that the Office of Research and Special Projects (ORSP) did not complete the review of their compliance reports within six months of acceptance of the audit report by the FAC. Cause and Effect The ORSP lost two full time personnel in summer of 2020, one of whom was responsible for the review of the subrecipient compliance reports and issuing the management decision for any audit findings. That position was not filled until the December 2021 and no one else in ORSP completed these reviews during this timeframe. The lack of monitoring subrecipients timely could result in continuing to pass-through federal monies to a subrecipient who is not in compliance with federal compliance. Noncompliance by a subrecipient that is not identified and addressed timely could jeopardize the University?s receipt of future federal awards and public reputation. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, finding 2021-001 Recommendation We recommend that Lehigh University strengthen its processes and controls to ensure the review of its subrecipient?s compliance reports is completed within six months of acceptance of the audit report by the FAC. Views of Responsible Officials Lehigh University accepts this finding. The review of fiscal year 2022 has been conducted and is complete for the review of those institutions who have submitted their audit reports to the Federal Audit Clearinghouse.
Subrecipient Monitoring Material Weakness Material Noncompliance 2022-023 Strengthen Controls to Ensure Compliance with Subrecipient Monitoring Requirements. ALN Number 17.258, 17.259, 17.278- Workforce Innovation and Opportunity Act Federal Award No. NIA Federal Agency Department of Labor Pass-through Entity NI A Questioned Costs NI A Criteria Code of Federal Regulations (2 CFR ?200.332(f)) states all pass-through entities (PTE?s) must verify that every subrecipient is audited as required by Subpart F - Audit Requirements when it is expected that the subrecipient's Federal awards expended during the fiscal year equaled or exceeded the threshold?a non- Federal entity that expends $750,000 or more during the non-Federal entity?s fiscal year in Federal awards must have a single audit conducted?set forth in ? 200.501 Audit requirements. Code of Federal Regulations 2 CFR 200.332 (d) states to 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. Sec. 184(a)(4) of the Workforce Innovation and Opportunity Act states the State must conduct an annual on-site monitoring review of each local area?s compliance with 2 CFR part 200. Code of Federal Regulations 2 CFR 200.332 (e) states depending upon the passthrough entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in ? 200.425. Condition The Mississippi Department of Employment Security (MDES) does not efficiently or effectively review the required federal audits for Subrecipient Monitoring Requirements per 2 CFR 200.332 (f). For three out of thirteen subrecipients the agency did not maintain or provide the correct Single Audit or the determination if a Single Audit was required when requested. MDES does not appropriately ensure on-site monitoring is done in a timely manner. During review of ten subrecipients, auditor noted that all documented monitoring was done after the fiscal year was complete, the monitoring was not completed on-site, and the reports for the monitoring were provided back to the agency after the fiscal year was complete. Per discussion with agency personnel, a pre-award scoring is being performed to determine ability of the subrecipient to enact the grant, however a risk based assessment to ensure the subrecipient has proper accountability with the award is not being performed. Cause Staff did not follow policies and procedures for subrecipient on-site monitoring requirements. Effect Subrecipients could be in noncompliance with 2 CFR ? 200.501, Audit requirements, and go undetected by MDES. In addition, MDES could lose federal funding for not properly monitoring their subrecipients. Without proper monitoring of their federal reports, subrecipients may participate in unallowable activities that goes undetected by MDES, the grantor. Recommendation We recommend that the Mississippi Department Employment Security strengthen controls to ensure compliance with the Subrecipient Monitoring requirements. Repeat Finding No. Statistically Valid No.
Subrecipient Monitoring Material Weakness Material Noncompliance 2022-023 Strengthen Controls to Ensure Compliance with Subrecipient Monitoring Requirements. ALN Number 17.258, 17.259, 17.278- Workforce Innovation and Opportunity Act Federal Award No. NIA Federal Agency Department of Labor Pass-through Entity NI A Questioned Costs NI A Criteria Code of Federal Regulations (2 CFR ?200.332(f)) states all pass-through entities (PTE?s) must verify that every subrecipient is audited as required by Subpart F - Audit Requirements when it is expected that the subrecipient's Federal awards expended during the fiscal year equaled or exceeded the threshold?a non- Federal entity that expends $750,000 or more during the non-Federal entity?s fiscal year in Federal awards must have a single audit conducted?set forth in ? 200.501 Audit requirements. Code of Federal Regulations 2 CFR 200.332 (d) states to 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. Sec. 184(a)(4) of the Workforce Innovation and Opportunity Act states the State must conduct an annual on-site monitoring review of each local area?s compliance with 2 CFR part 200. Code of Federal Regulations 2 CFR 200.332 (e) states depending upon the passthrough entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in ? 200.425. Condition The Mississippi Department of Employment Security (MDES) does not efficiently or effectively review the required federal audits for Subrecipient Monitoring Requirements per 2 CFR 200.332 (f). For three out of thirteen subrecipients the agency did not maintain or provide the correct Single Audit or the determination if a Single Audit was required when requested. MDES does not appropriately ensure on-site monitoring is done in a timely manner. During review of ten subrecipients, auditor noted that all documented monitoring was done after the fiscal year was complete, the monitoring was not completed on-site, and the reports for the monitoring were provided back to the agency after the fiscal year was complete. Per discussion with agency personnel, a pre-award scoring is being performed to determine ability of the subrecipient to enact the grant, however a risk based assessment to ensure the subrecipient has proper accountability with the award is not being performed. Cause Staff did not follow policies and procedures for subrecipient on-site monitoring requirements. Effect Subrecipients could be in noncompliance with 2 CFR ? 200.501, Audit requirements, and go undetected by MDES. In addition, MDES could lose federal funding for not properly monitoring their subrecipients. Without proper monitoring of their federal reports, subrecipients may participate in unallowable activities that goes undetected by MDES, the grantor. Recommendation We recommend that the Mississippi Department Employment Security strengthen controls to ensure compliance with the Subrecipient Monitoring requirements. Repeat Finding No. Statistically Valid No.
Subrecipient Monitoring Material Weakness Material Noncompliance 2022-023 Strengthen Controls to Ensure Compliance with Subrecipient Monitoring Requirements. ALN Number 17.258, 17.259, 17.278- Workforce Innovation and Opportunity Act Federal Award No. NIA Federal Agency Department of Labor Pass-through Entity NI A Questioned Costs NI A Criteria Code of Federal Regulations (2 CFR ?200.332(f)) states all pass-through entities (PTE?s) must verify that every subrecipient is audited as required by Subpart F - Audit Requirements when it is expected that the subrecipient's Federal awards expended during the fiscal year equaled or exceeded the threshold?a non- Federal entity that expends $750,000 or more during the non-Federal entity?s fiscal year in Federal awards must have a single audit conducted?set forth in ? 200.501 Audit requirements. Code of Federal Regulations 2 CFR 200.332 (d) states to 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. Sec. 184(a)(4) of the Workforce Innovation and Opportunity Act states the State must conduct an annual on-site monitoring review of each local area?s compliance with 2 CFR part 200. Code of Federal Regulations 2 CFR 200.332 (e) states depending upon the passthrough entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in ? 200.425. Condition The Mississippi Department of Employment Security (MDES) does not efficiently or effectively review the required federal audits for Subrecipient Monitoring Requirements per 2 CFR 200.332 (f). For three out of thirteen subrecipients the agency did not maintain or provide the correct Single Audit or the determination if a Single Audit was required when requested. MDES does not appropriately ensure on-site monitoring is done in a timely manner. During review of ten subrecipients, auditor noted that all documented monitoring was done after the fiscal year was complete, the monitoring was not completed on-site, and the reports for the monitoring were provided back to the agency after the fiscal year was complete. Per discussion with agency personnel, a pre-award scoring is being performed to determine ability of the subrecipient to enact the grant, however a risk based assessment to ensure the subrecipient has proper accountability with the award is not being performed. Cause Staff did not follow policies and procedures for subrecipient on-site monitoring requirements. Effect Subrecipients could be in noncompliance with 2 CFR ? 200.501, Audit requirements, and go undetected by MDES. In addition, MDES could lose federal funding for not properly monitoring their subrecipients. Without proper monitoring of their federal reports, subrecipients may participate in unallowable activities that goes undetected by MDES, the grantor. Recommendation We recommend that the Mississippi Department Employment Security strengthen controls to ensure compliance with the Subrecipient Monitoring requirements. Repeat Finding No. Statistically Valid No.