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.
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.