FINDING 2024-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Indiana Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-010. Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. Even though the reports were reviewed by someone other than the preparer, the School Corporation was not able to provide financial information that was used to determine amounts used in the reports. The School Corporation completed and submitted four annual Data Collection reports (Reports) for the Elementary and Secondary School Emergency Relief (ESSER) grants. For all four of the Reports, the School Corporation was unable to provide financial information to support the amounts in the Reports; therefore, the Indiana State Board of Accounts could not determine the accuracy of the Reports. Additionally, eight of eight key line items selected for testing could not be verified to the financial records. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause According to the School Corporation, these issues were due to the reporting differences of how the annual expenditure report categories are different than the annual Data Collection reports. The School Corporation indicated that it had to go employee by employee to properly place them under the correct category using the reimbursement requests but did not retain that documentation of how it came to the numbers. Effect The failure to design and implement an effective internal control system enabled noncompliance to go undetected with the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish effective internal controls to ensure reports submitted are accurate and have supporting documentation. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.