Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. Condition: The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe. Cause: Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process. Effect or Potential Effect: The University was not in compliance with certain subrecipient monitoring requirements during the year. Questioned Costs: None. Context: We noted the following in during our testing: • For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university. • For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices. Views of Responsible Officials: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Assistance Listing 14.267 Continuum of Care Program Condition: For two out of 51 tested transactions, the Office of Homeless Services (OHS) charged to the grant a total of $63,816 in expenditures that were incurred after the established period of performance. Also, an additional three expenditure transactions were not liquidated within 120 calendar days after the end date of the period of performance; however, we are not questioning costs related to these transactions, as they are otherwise in compliance with period of performance regulations. Funding for this program is received from the U.S. Department of Housing and Urban Development. Criteria: Per 2 CFR section 200.403(h), costs must be incurred during the approved budget period. Also, per 2 CFR section 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the federal award. Effect: Failure to incur expenditures and liquidate financial obligations within the required time period can result in noncompliance for the program as well as questioned costs and repayment obligations. Total expenditures of $63,816 incurred after the period of performance are considered to be known questioned costs. Cause: For most of the transactions noted in the condition, period of performance issues were the result of the timing of vendor invoice submissions. Additionally, OHS expenditure review procedures did not detect the noncompliance. Recommendation:We recommend that OHS improve the efficiency of communications with their vendors to stress the importance of timely invoice submissions. OHS should also strengthen expenditure review procedures to detect future noncompliance. Views of the Responsible Officials and Corrective Action Plan: OHS agrees with the issues outlined, which stem from the delayed processing of invoices and untimely payments. These challenges are largely the result of longstanding issues with over-allocations and the need to catch up on processing a backlog of documents. We appreciate you bringing this to our attention, as it provides an opportunity to refine our procedures and put in place measures to prevent these issues from recurring in the future. This feedback will be valuable as we work to improve our processes and enhance our ability to manage workloads more effectively. Contact Person: Jerome R. Hill, Director of Compliance, Office of Homeless Services, 215-686-0371, 215-520-3556
CONDITION: The District did not comply with the laws and regulations related to its participation in it’s various federal grant program reporting requirements. Personnel did not complete and submit the required ‘quarterly cash on hand reports’ and ‘final expenditure report’ (FER) for the grant programs based on supporting accurate general ledger expenditures as required by Section 2 CFR 200.403(g) of the Uniform Guidance. This is a repeat finding from (2022-002) from the previous fiscal year. CRITERIA: The PA Department of Education (PDE) and Section 2 CFR 200.403(g) of the Uniform Guidance requires the completion and submission of a ‘quarterly cash on hand report’ quarterly as needed and a ‘final expenditure report’ (FER) at the conclusion of each grant program year (including any carryover period) based on information contained in the School District’s financial management system and supported by all underlying documentation. EFFECT: The District was not in compliance with the PA Department of Education (PDE) and Section 2 CFR 200.403(g) of the Uniform Guidance financial reporting requirements relative to its participation the ESSER and ARP ESSER grant programs that require submission of ‘quarterly cash on hand reports’ and a ‘final expenditure report’ (FER) based on supporting accurate financial management system expenditures. CAUSE: The District experienced turnover in key business office personnel during the last two fiscal years, which resulted in errors in posting federal expenditures to the appropriate general ledger account codes. This further lead to inaccurate reporting as outlined above. QUESTIONED COST: None RECOMMENDATION: I recommend that the District re-file the required federal program ‘final expenditure reports’, if possible, based on accurate financial information obtained from the District’s financial management system after any corrections are made, in order to 1) comply with PDE and Uniform Guidance reporting requirements for the District’s applicable federal programs, and 2) to avoid any sanctions from PDE as a result of not filing these reports properly with accurate general ledger detail in a timely manner. All further federal grant reporting should be completed based on accurate general ledger expenditures. VIEW OF RESPONSIBLE OFFICIALS: See Correction Action Plan
CONDITION: The District did not comply with the laws and regulations related to its participation in it’s various federal grant program reporting requirements. Personnel did not complete and submit the required ‘quarterly cash on hand reports’ and ‘final expenditure report’ (FER) for the grant programs based on supporting accurate general ledger expenditures as required by Section 2 CFR 200.403(g) of the Uniform Guidance. This is a repeat finding from (2022-002) from the previous fiscal year. CRITERIA: The PA Department of Education (PDE) and Section 2 CFR 200.403(g) of the Uniform Guidance requires the completion and submission of a ‘quarterly cash on hand report’ quarterly as needed and a ‘final expenditure report’ (FER) at the conclusion of each grant program year (including any carryover period) based on information contained in the School District’s financial management system and supported by all underlying documentation. EFFECT: The District was not in compliance with the PA Department of Education (PDE) and Section 2 CFR 200.403(g) of the Uniform Guidance financial reporting requirements relative to its participation the ESSER and ARP ESSER grant programs that require submission of ‘quarterly cash on hand reports’ and a ‘final expenditure report’ (FER) based on supporting accurate financial management system expenditures. CAUSE: The District experienced turnover in key business office personnel during the last two fiscal years, which resulted in errors in posting federal expenditures to the appropriate general ledger account codes. This further lead to inaccurate reporting as outlined above. QUESTIONED COST: None RECOMMENDATION: I recommend that the District re-file the required federal program ‘final expenditure reports’, if possible, based on accurate financial information obtained from the District’s financial management system after any corrections are made, in order to 1) comply with PDE and Uniform Guidance reporting requirements for the District’s applicable federal programs, and 2) to avoid any sanctions from PDE as a result of not filing these reports properly with accurate general ledger detail in a timely manner. All further federal grant reporting should be completed based on accurate general ledger expenditures. VIEW OF RESPONSIBLE OFFICIALS: See Correction Action Plan
CONDITION: The District did not comply with the laws and regulations related to its participation in it’s various federal grant program reporting requirements. Personnel did not complete and submit the required ‘quarterly cash on hand reports’ and ‘final expenditure report’ (FER) for the grant programs based on supporting accurate general ledger expenditures as required by Section 2 CFR 200.403(g) of the Uniform Guidance. This is a repeat finding from (2022-002) from the previous fiscal year. CRITERIA: The PA Department of Education (PDE) and Section 2 CFR 200.403(g) of the Uniform Guidance requires the completion and submission of a ‘quarterly cash on hand report’ quarterly as needed and a ‘final expenditure report’ (FER) at the conclusion of each grant program year (including any carryover period) based on information contained in the School District’s financial management system and supported by all underlying documentation. EFFECT: The District was not in compliance with the PA Department of Education (PDE) and Section 2 CFR 200.403(g) of the Uniform Guidance financial reporting requirements relative to its participation the ESSER and ARP ESSER grant programs that require submission of ‘quarterly cash on hand reports’ and a ‘final expenditure report’ (FER) based on supporting accurate financial management system expenditures. CAUSE: The District experienced turnover in key business office personnel during the last two fiscal years, which resulted in errors in posting federal expenditures to the appropriate general ledger account codes. This further lead to inaccurate reporting as outlined above. QUESTIONED COST: None RECOMMENDATION: I recommend that the District re-file the required federal program ‘final expenditure reports’, if possible, based on accurate financial information obtained from the District’s financial management system after any corrections are made, in order to 1) comply with PDE and Uniform Guidance reporting requirements for the District’s applicable federal programs, and 2) to avoid any sanctions from PDE as a result of not filing these reports properly with accurate general ledger detail in a timely manner. All further federal grant reporting should be completed based on accurate general ledger expenditures. VIEW OF RESPONSIBLE OFFICIALS: See Correction Action Plan
CONDITION: The District did not comply with the laws and regulations related to its participation in it’s various federal grant program reporting requirements. Personnel did not complete and submit the required ‘quarterly cash on hand reports’ and ‘final expenditure report’ (FER) for the grant programs based on supporting accurate general ledger expenditures as required by Section 2 CFR 200.403(g) of the Uniform Guidance. This is a repeat finding from (2022-002) from the previous fiscal year. CRITERIA: The PA Department of Education (PDE) and Section 2 CFR 200.403(g) of the Uniform Guidance requires the completion and submission of a ‘quarterly cash on hand report’ quarterly as needed and a ‘final expenditure report’ (FER) at the conclusion of each grant program year (including any carryover period) based on information contained in the School District’s financial management system and supported by all underlying documentation. EFFECT: The District was not in compliance with the PA Department of Education (PDE) and Section 2 CFR 200.403(g) of the Uniform Guidance financial reporting requirements relative to its participation the ESSER and ARP ESSER grant programs that require submission of ‘quarterly cash on hand reports’ and a ‘final expenditure report’ (FER) based on supporting accurate financial management system expenditures. CAUSE: The District experienced turnover in key business office personnel during the last two fiscal years, which resulted in errors in posting federal expenditures to the appropriate general ledger account codes. This further lead to inaccurate reporting as outlined above. QUESTIONED COST: None RECOMMENDATION: I recommend that the District re-file the required federal program ‘final expenditure reports’, if possible, based on accurate financial information obtained from the District’s financial management system after any corrections are made, in order to 1) comply with PDE and Uniform Guidance reporting requirements for the District’s applicable federal programs, and 2) to avoid any sanctions from PDE as a result of not filing these reports properly with accurate general ledger detail in a timely manner. All further federal grant reporting should be completed based on accurate general ledger expenditures. VIEW OF RESPONSIBLE OFFICIALS: See Correction Action Plan
CONDITION: The District did not comply with the laws and regulations related to its participation in it’s various federal grant program reporting requirements. Personnel did not complete and submit the required ‘quarterly cash on hand reports’ and ‘final expenditure report’ (FER) for the grant programs based on supporting accurate general ledger expenditures as required by Section 2 CFR 200.403(g) of the Uniform Guidance. This is a repeat finding from (2022-002) from the previous fiscal year. CRITERIA: The PA Department of Education (PDE) and Section 2 CFR 200.403(g) of the Uniform Guidance requires the completion and submission of a ‘quarterly cash on hand report’ quarterly as needed and a ‘final expenditure report’ (FER) at the conclusion of each grant program year (including any carryover period) based on information contained in the School District’s financial management system and supported by all underlying documentation. EFFECT: The District was not in compliance with the PA Department of Education (PDE) and Section 2 CFR 200.403(g) of the Uniform Guidance financial reporting requirements relative to its participation the ESSER and ARP ESSER grant programs that require submission of ‘quarterly cash on hand reports’ and a ‘final expenditure report’ (FER) based on supporting accurate financial management system expenditures. CAUSE: The District experienced turnover in key business office personnel during the last two fiscal years, which resulted in errors in posting federal expenditures to the appropriate general ledger account codes. This further lead to inaccurate reporting as outlined above. QUESTIONED COST: None RECOMMENDATION: I recommend that the District re-file the required federal program ‘final expenditure reports’, if possible, based on accurate financial information obtained from the District’s financial management system after any corrections are made, in order to 1) comply with PDE and Uniform Guidance reporting requirements for the District’s applicable federal programs, and 2) to avoid any sanctions from PDE as a result of not filing these reports properly with accurate general ledger detail in a timely manner. All further federal grant reporting should be completed based on accurate general ledger expenditures. VIEW OF RESPONSIBLE OFFICIALS: See Correction Action Plan
Assistance Lising number: 84.010 Program title: Title I Agency: U.S. Department of Education Pass-Through entity: Missouri Department of Elementary and Secondary Education Compliance Requirement: Allowable Costs Type of Finding: Material noncompliance Criteria: In accordance with 2 CFR 200.403, costs must be adequately documented to be allowable under Federal awards. Furthermore, under 2 CFR 200.431 employee benefit costs must be allocated to Federal awards in a manner consistent with the pattern of benefits attributable to the employees whose salaries and wages are chargeable to such Federal awards. Condition: We tested twenty-one transactions for employee benefits totaling $9,801 that were allocated to the Title I program general ledger. The Collaborative could not support these allocations. Cause: The Collaborative did not verify the accuracy of the allocation of employee benefits charged to the Title I general ledger by the payroll system. Effect: The allocation of employee benefit costs to the Title I program was not adequately supported as required by 2 CFR 200.403 for the transactions tested. Questioned costs: $9,801. Context: Total benefits charged to the Title 1 program were $337,839. Repeat finding: Not applicable. Recommendation: We recommend the Collaborative maintain a schedule detailing salary and benefit costs by employee for each Federal award. The Collaborative should recalculate the benefit costs for each employee to ensure their accuracy. Total salaries and benefits on the schedule should then be reconciled to the general ledger and to the Final Expenditure Report submitted to DESE. Views of the responsible officials and planned corrective actions: We will maintain a schedule that details all salary and benefit expenses charged against each Federal award and ensure that these totals are reconciled back to the general ledger and the Final Expenditure Report. We take some exception with this finding, as we believe the audit sample was pulled and formatted in a cumbersome manner and did not facilitate the process of clearly identifying all of the expenditures cited, which often represented portions of benefit costs paid for personnel and reflected in total on related insurance invoices, etc. The Director of Federal Programs and the Payroll Coordinator will be charged with ensuring the accuracy of this information and the related processes moving forward.