Federal Grantor: Department of Labor Pass-Through: Iowa Workforce Development Program: Workforce Innovation and Opportunity Act (WIOA) Cluster Award No. and Year: 24-N-CI-WI-OA and 2024 Federal Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: 2 CFR 200.332(b) – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors listed in 2 CFR 200.332(b)(1) through (4). 2 CFR 200.332(d) – 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. Pass-through entity monitoring of the subrecipient must include the information at 2 CFR 200.332(d)(1) through (4). 2 CFR 200.332(f) – Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. Condition: The County did not have any formal controls in place for evaluating each subrecipient’s risk of noncompliance or the purpose of determining the appropriate subrecipient monitoring for the WIOA Cluster. Cause: The County did not follow their procedures to evaluate the risk of noncompliance or monitor the activities of each subrecipient, and the County did not maintain documentation of their verification that every subrecipient is audited, as required. Effect: The County’s control policies were not consistently followed which require compliance with Subrecipient Monitoring requirements in 2 CFR 200.332 and did not comply with subrecipient monitoring requirements related to the program. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for testing. The condition noted above was identified during our procedures related to subrecipient monitoring and was pervasive to the program. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County adhere to their policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Finding Number: 2024-003 Program: Housing Opportunities for Persons with AIDS (HOPWA) ALN #: 14.241 Pass-through Entity: N/A- Direct Award Federal Agency: Department of Housing and Urban Development Federal Award Year: July 1, 2023–June 30, 2024 Compliance Requirement: Subrecipient Monitoring Type of finding: Material weakness and material noncompliance Criteria The 2 CFR sections 200.332(d) through (f) provide the principles to be applied to 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. According to 2 CFR 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition The City does not have properly designed controls and documented procedures in place to ensure compliance with the following requirements: • Each subrecipients risk of noncompliance is appropriately evaluated. • Appropriate monitoring of the subrecipient based on their risk of noncompliance. • Verification that subrecipients are audited as required when they are expected to exceed the threshold for having a single audit. Cause The City does not have formal written policies, procedures, and internal controls in place to ensure that all required subrecipient monitoring procedures are performed. Proper perspective During our audit, we noted that four of the four subrecipients selected for testing did not have a completed risk assessment to determine their risk of noncompliance. As such, we were unable to determine that the proper level of monitoring was completed throughout the fiscal year over the contracted subrecipient. Additionally, we noted that the audited financial statements were obtained for the four subrecipients selected for testing, but there was no documentation to evidence the nature and extent of the City’s review of the reports obtained. Possible asserted effect Lack of effective controls and written policies and procedures over subrecipient monitoring could result in the City’s noncompliance with program requirements. Questioned costs None Statistical sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat finding Yes, 2023-005 Recommendation We recommend the City establish a checklist or formal documentation requirements for both risk assessments and review of single audit report procedures. Employees can complete these checklists when obtaining and reviewing the documentation. The City should then conclude on and document the subrecipient’s risk of noncompliance based on the checklist to ensure the proper level of monitoring occurs throughout the year. Views of responsible officials and corrective actions The City has addressed this recommendation. The City has updated policies and procedures in place. A standardized Subrecipient Audit Risk Assessment Checklist is in place and a Monitoring Risk Assessment Checklist has also been developed and implemented to guide and document the evaluation of subrecipient risk, review of single audit reports, monitoring. Federal Grants Division staff will complete this checklist during the initial subrecipient review and update it annually. This will ensure consistent documentation of each subrecipient's risk level and corresponding compliance requirements. The process will enable the City to make informed decisions regarding the appropriate level of monitoring for each subrecipient, based on the risk assessment outcomes. This systematic approach enhances accountability, supports audit readiness, and aligns with federal guidance under 2 CFR Part 200. All the agencies/subrecipients have been informed of the upcoming monitoring.
Finding Number: 2024-009 Program: Coronavirus State and Local Fiscal Recovery Funds ALN #: 21.027 Pass-through Entity: N/A- Direct Award Federal Agency: U.S. Department of Treasury Federal Award Year: July 1, 2023–June 30, 2024 Compliance Requirement: Subrecipient Monitoring Type of finding: Material weakness and material noncompliance Criteria The 2 CFR sections 200.332(d) through (f) provide the principles to be applied to 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. According to 2 CFR 200.303, the non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition The City does not have properly designed controls and documented procedures in place to ensure compliance with the following requirements: • Each subrecipients risk of noncompliance is appropriately evaluated. • Verification that subrecipients are audited as required when they are expected to exceed the threshold for having a single audit. • All required elements of the subrecipient contracts are included during execution. Cause The City’s lack of effective internal controls and written policies and procedures have caused the following Proper perspective During the audit, we noted that eight of the nine subrecipient selections did not contain all the required elements of the contract. Additionally, nine of the nine selections completed a risk assessment questionnaire. However, there is no indication that the City reviewed the questionnaires and subsequently concluded on the subrecipient’s risk of noncompliance. We also noted that audited financial statements were obtained for the three subrecipients that required a single audit, but there was no documentation to evidence the nature and extent of the City’s review of the audit reports obtained. Therefore, we were unable to determine if, based on the subrecipient’s risk assessment questionnaire and single audit report, if additional monitoring procedures were required Possible asserted effect Lack of effective controls and written policies and procedures over subrecipient monitoring could result in the City’s noncompliance with program requirements. Questioned costs None Statistical sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes, 2023-009 Recommendation We recommend the City establish a checklist or formal documentation requirements for both risk assessments and review of single audit report procedures. Employees can complete these checklists when obtaining and reviewing the documentation. The City should then conclude on and document the subrecipient’s risk of noncompliance based on the checklist to ensure the proper level of monitoring occurs throughout the year. Views of responsible officials and corrective actions The City has implemented additional controls over subrecipient monitoring by establishing a formal policy to review and document subrecipient qualifications, risk assessments and financial reports and have created subsequent monitoring plans and checklists. noncompliance and control exceptions.
Condition: We tested 100% of the eleven (11) subrecipients and noted the following: • The County failed to adequately monitor the subrecipients. • The contracts did not clearly identify the vendor as a subrecipient relationship. • Funds were not encumbered at the time of the notice to proceed was given to subrecipients. The subrecipients approved by the Board of County Commissioners state that subrecipients or beneficiaries shall provide monthly performance reports until all award funds hereunder have been expended. Through the observation of records, it was determined that monthly performance reports were not submitted each month by entities receiving funding. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are made in accordance with compliance requirements. Effect of Condition: This condition resulted in noncompliance with federal grant guidelines. Recommendation: OSAI recommends the County gain an understanding of the requirements for this program and implement internal controls to ensure compliance with these requirements. Management Response: BOCC Chairman: Board of County Commissioners: The Board of County Commissioners is responsible for the overall fiscal concerns of the county. See OKLA. STAT. Title 19, § 345. The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The Board of County Commissioners will work with all elected officials, the third-party administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. These policies and procedures will be designed to identify requirements for recipients and sub-recipients of grants, ensure accurate equipment and real property management, procurement, recipient and subrecipient monitoring and reporting. Further, policies will ensure a proper understanding of all grant requirements and compliance of the same. To assist in this process, the Board of County Commissioners engaged a third-party administrator to oversee the grant process, including application, eligibility, review, requirements, contracting, recipient tracking and oversight, and documentation and reporting. The Board of County Commissioners will work with the third-party administrator to ensure proper grant administration. Criteria: 2 CFR 200 §200.332 Requirement for Pass-Through Entities states in part: All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. (2) All requirements imposed by the pass-through entity on the subrecipient so that the federal award is used in accordance with federal statutes, regulations and the terms and conditions of the federal award. (5) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the pass-through entity to meet the requirements of this part. (6) Appropriate terms and conditions concerning closeout of the subaward.
System of Internal Controls Over Compliance: Subrecipient Monitoring; U.S. Department of Treasury, Assistance Listing #21.027, Coronavirus State and Local Fiscal Recovery Funds, Passed Through State of Nevada Criteria: In accordance with 2 CFR 200.332, the auditee must maintain a system of internal control over compliance to ensure they provide each subrecipient within the required information to identify the award and applicable requirements under the award and to evaluate risk and monitor the activities of each subrecipient to ensure compliance under the award. Condition: The Organization did not appropriately implement internal controls necessary to ensure appropriate documentation was available to support the performance of controls in compliance with 2 CFR 200.332. Context: The Organization did not identify funds being passed through from one subsidiary of the Organization to a second subsidiary in a timely manner and based on this timing did not appropriately document the performance of internal controls over the compliance for subrecipient monitoring. Cause: The Organization did not identify its only subrecipient for this award in a timely manner. Effect: The Organization was not able to properly document its performance of internal controls over most of the requirements outlined in 2 CFR 200.332 for the award based on untimely identification of its subrecipient. Recommendation: We recommend management design and implement a system of internal controls over compliance where consideration of possible subrecipients is considered when the award is being applied for and that well documented and supportable internal controls over subrecipient monitoring are implemented when there are subrecipients identified under an award. Repeat Finding: No Views of Responsible Officials and Planned Corrective Actions: SJRC NV Region is addressing its missing controls related to the requirements of 2 CFR 200.332. We acknowledge that SJRC must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information required under 2 CFR 200.332 at the time of the subaward all requirements. This includes that every subaward is clearly identified to the subrecipient as a subaward and includes at the time of the subaward and if any data elements change, that there must be an approved subaward modification. We will also ensure we meet the requirements under 2 CFR 200.332 to include our obligations to risk assess and monitor any subrecipients. The timeframe for correction is immediate and full accounting system control improvements will be implemented as part of our 2025 fiscal year-end close.
Program: Assistance Listing Number 59.059 – Congressional Earmarks Initiative Awarding Agency – U.S. Small Business Association Grant Number – SBAHQ23I0008 Federal Award Year – 2024 Questioned Cost: None. Criteria: Per 2 CFR 200.332, Central Michigan University Research Corporation is required to perform risk assessment and monitoring procedures for subrecipients of federal grants. This includes procedures such as evaluating the subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward, review of financial and performance reports, and follow up of the subrecipient’s correction of previous Single Audit findings. Condition: The Organization lacked documentation that sufficient subrecipient risk assessment and monitoring procedures were performed as required by Uniform Guidance. An assumption was made that because the subrecipient was to receive funding as part of a federal mandate that the Organization’s only responsibility was to pass through the funding. Cause / Effect: Management does not have the proper policies and procedures in place to ensure that the required subrecipient procedures are being performed, causing noncompliance. Recommendation: We recommend that management reviews the required procedures for pass-through entities as listed in 2 CFR 200.332 and implements the procedures accordingly. This should include documented risk assessment and monitoring procedures for all subrecipient of federal awards. Views of Responsible Officials: Management agrees with the finding. Corrective Action Plan: See attached corrective action plan from management.
2024 – 002: Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis response Assistance Listing Number: 93.354 Federal Award Identification Number: NU90TP922168, NU90TP921992 Pass-Through Agency: South Carolina Department of Health and Environmental Control Pass-Through Numbers: PH-2-533, CY-19-018 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance - Per 2 CFR section 200.332(a), the subaward is to clearly identify to the subrecipient required information, including identification of whether the award is R&D. Condition: The University incorrectly documented the subaward as a Research and Development grant to the subrecipient. Questioned costs: None Context: This condition occurred for 5 out of 5 subawards selected for testing. Cause: Attachment 2 of the Federal Awards Terms and Conditions template of the FDP Cost Reimbursement Subaward includes a field that is pre-selected and defaults to the R&D selection, requiring the field to be unchecked for the subawards that are not classified as R&D. Effect: The subrecipient may not be aware of certain award information in order to comply with federal statutes, regulations, and the terms and conditions of the award and properly classify its schedule of expenditures of federal awards. Repeat Finding: No Recommendation: We recommend the University strengthen its internal controls to ensure that subawards report the correct information. Views of responsible officials: Management acknowledges the finding.
2024 – 002: Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis response Assistance Listing Number: 93.354 Federal Award Identification Number: NU90TP922168, NU90TP921992 Pass-Through Agency: South Carolina Department of Health and Environmental Control Pass-Through Numbers: PH-2-533, CY-19-018 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance - Per 2 CFR section 200.332(a), the subaward is to clearly identify to the subrecipient required information, including identification of whether the award is R&D. Condition: The University incorrectly documented the subaward as a Research and Development grant to the subrecipient. Questioned costs: None Context: This condition occurred for 5 out of 5 subawards selected for testing. Cause: Attachment 2 of the Federal Awards Terms and Conditions template of the FDP Cost Reimbursement Subaward includes a field that is pre-selected and defaults to the R&D selection, requiring the field to be unchecked for the subawards that are not classified as R&D. Effect: The subrecipient may not be aware of certain award information in order to comply with federal statutes, regulations, and the terms and conditions of the award and properly classify its schedule of expenditures of federal awards. Repeat Finding: No Recommendation: We recommend the University strengthen its internal controls to ensure that subawards report the correct information. Views of responsible officials: Management acknowledges the finding.
2024-003 Subrecipient Monitoring Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: Per 2 CFR sections 200.332(d) through (f), a pass-through entity 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 the performance goals. Per 2 CFR section 200.502(a), the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs which is generally expenditure/expense transactions associated with awards. Condition: Subrecipients were not monitored timely enough to perform the necessary evaluation on subrecipient activities or to report expenditures on the schedule of expenditures of federal awards in the appropriate fiscal year. Cause: UAS did not receive invoices for certain subrecipients until after year-end close and for amounts covering an entire fiscal year and no amounts were accrued. Effect: Activities of the subrecipient could not be reviewed timely to ensure authorized use or for allowability with grant terms and conditions. Subrecipient expenditures on the schedule of expenditures of federal awards were understated by $344,948. Questioned Costs: The conditions did not result in questioned costs greater than $25,000. Context: Although subrecipient invoices were submitted after year-end close, UAS grant personnel reviewed expenses submitted for allowability and did not identify any disallowed costs. Repeat Finding: No. Recommendation: Establish a timeline for subrecipients to provide required reports to UAS in order to receive information during the fiscal year for monitoring during the post-award process. Review grant and subrecipient activity at year-end to evaluate whether all activity has been submitted and recorded. Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-003 Subrecipient Monitoring Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: Per 2 CFR sections 200.332(d) through (f), a pass-through entity 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 the performance goals. Per 2 CFR section 200.502(a), the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs which is generally expenditure/expense transactions associated with awards. Condition: Subrecipients were not monitored timely enough to perform the necessary evaluation on subrecipient activities or to report expenditures on the schedule of expenditures of federal awards in the appropriate fiscal year. Cause: UAS did not receive invoices for certain subrecipients until after year-end close and for amounts covering an entire fiscal year and no amounts were accrued. Effect: Activities of the subrecipient could not be reviewed timely to ensure authorized use or for allowability with grant terms and conditions. Subrecipient expenditures on the schedule of expenditures of federal awards were understated by $344,948. Questioned Costs: The conditions did not result in questioned costs greater than $25,000. Context: Although subrecipient invoices were submitted after year-end close, UAS grant personnel reviewed expenses submitted for allowability and did not identify any disallowed costs. Repeat Finding: No. Recommendation: Establish a timeline for subrecipients to provide required reports to UAS in order to receive information during the fiscal year for monitoring during the post-award process. Review grant and subrecipient activity at year-end to evaluate whether all activity has been submitted and recorded. Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-003 Subrecipient Monitoring Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: Per 2 CFR sections 200.332(d) through (f), a pass-through entity 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 the performance goals. Per 2 CFR section 200.502(a), the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs which is generally expenditure/expense transactions associated with awards. Condition: Subrecipients were not monitored timely enough to perform the necessary evaluation on subrecipient activities or to report expenditures on the schedule of expenditures of federal awards in the appropriate fiscal year. Cause: UAS did not receive invoices for certain subrecipients until after year-end close and for amounts covering an entire fiscal year and no amounts were accrued. Effect: Activities of the subrecipient could not be reviewed timely to ensure authorized use or for allowability with grant terms and conditions. Subrecipient expenditures on the schedule of expenditures of federal awards were understated by $344,948. Questioned Costs: The conditions did not result in questioned costs greater than $25,000. Context: Although subrecipient invoices were submitted after year-end close, UAS grant personnel reviewed expenses submitted for allowability and did not identify any disallowed costs. Repeat Finding: No. Recommendation: Establish a timeline for subrecipients to provide required reports to UAS in order to receive information during the fiscal year for monitoring during the post-award process. Review grant and subrecipient activity at year-end to evaluate whether all activity has been submitted and recorded. Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-003 Subrecipient Monitoring Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: Per 2 CFR sections 200.332(d) through (f), a pass-through entity 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 the performance goals. Per 2 CFR section 200.502(a), the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs which is generally expenditure/expense transactions associated with awards. Condition: Subrecipients were not monitored timely enough to perform the necessary evaluation on subrecipient activities or to report expenditures on the schedule of expenditures of federal awards in the appropriate fiscal year. Cause: UAS did not receive invoices for certain subrecipients until after year-end close and for amounts covering an entire fiscal year and no amounts were accrued. Effect: Activities of the subrecipient could not be reviewed timely to ensure authorized use or for allowability with grant terms and conditions. Subrecipient expenditures on the schedule of expenditures of federal awards were understated by $344,948. Questioned Costs: The conditions did not result in questioned costs greater than $25,000. Context: Although subrecipient invoices were submitted after year-end close, UAS grant personnel reviewed expenses submitted for allowability and did not identify any disallowed costs. Repeat Finding: No. Recommendation: Establish a timeline for subrecipients to provide required reports to UAS in order to receive information during the fiscal year for monitoring during the post-award process. Review grant and subrecipient activity at year-end to evaluate whether all activity has been submitted and recorded. Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
Criteria: According to grant terms & conditions and 2 CFR Section 200.332, all awardees of applicable grants and cooperative agreements are required to report to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) on all subawards over $30,000. Condition: The Commission did not provide timely FFATA reporting for ALN #11.469 and #11.472 subawards subject to the FFATA reporting requirements. Context: This is a condition identified based on review of grant terms and conditions and 2 CFR Section 200.332. Cause: The Commission was not aware of this reporting requirement. Effect: The Commission is not in compliance with FFATA reporting requirements for fiscal year 2024. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: We suggest that management review all awards for subrecipients and ensure that FFATA reporting is completed in a timely manner for subawards subject to the requirements. Views of Responsible Officials: The Commission agrees with the finding. Planned Corrective Action: The Commission will review all subawards for subrecipients and ensure that FFATA reporting is completed in a timely manner for subawards subject to the requirements. The Commission will add a clause in our Sub-awards stating this requirement. Responsible Official: Laura Leach, Director of Finance and Administration Anticipated Completion Date: December 31, 2024
Criteria: According to grant terms & conditions and 2 CFR Section 200.332, all awardees of applicable grants and cooperative agreements are required to report to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) on all subawards over $30,000. Condition: The Commission did not provide timely FFATA reporting for ALN #11.469 and #11.472 subawards subject to the FFATA reporting requirements. Context: This is a condition identified based on review of grant terms and conditions and 2 CFR Section 200.332. Cause: The Commission was not aware of this reporting requirement. Effect: The Commission is not in compliance with FFATA reporting requirements for fiscal year 2024. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: We suggest that management review all awards for subrecipients and ensure that FFATA reporting is completed in a timely manner for subawards subject to the requirements. Views of Responsible Officials: The Commission agrees with the finding. Planned Corrective Action: The Commission will review all subawards for subrecipients and ensure that FFATA reporting is completed in a timely manner for subawards subject to the requirements. The Commission will add a clause in our Sub-awards stating this requirement. Responsible Official: Laura Leach, Director of Finance and Administration Anticipated Completion Date: December 31, 2024
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.