2 CFR 200 § 200.403

Findings Citing § 200.403

Factors affecting allowability of costs.

Total Findings
10,492
Across all audits in database
Showing Page
190 of 210
50 findings per page
About this section
Section 200.403 outlines the criteria for costs to be allowable under Federal awards, requiring them to be necessary, reasonable, and properly documented, among other conditions. This affects recipients of Federal funding, ensuring they adhere to specific guidelines for cost management and reporting.
View full section details →
FY End: 2022-06-30
Charles County Public Schools
Compliance Requirement: H
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or spe...

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.

FY End: 2022-06-30
Charles County Public Schools
Compliance Requirement: H
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or spe...

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.

FY End: 2022-06-30
Charles County Public Schools
Compliance Requirement: H
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or spe...

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.

FY End: 2022-06-30
Charles County Public Schools
Compliance Requirement: H
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or spe...

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.

FY End: 2022-06-30
Charles County Public Schools
Compliance Requirement: H
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or spe...

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.

FY End: 2022-06-30
Hall County Board of Education
Compliance Requirement: ABI
FA 2022-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund C...

FA 2022-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $116,610 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to the coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $20,854,735 were expended and reported on the Hall County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 202.403 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed the following deficiencies: ? Bonuses totaling $20,344 were paid to individuals who were not employees of the School District. These individuals were hired to perform specific functions as detailed within the associated contracts and were paid amounts in excess of the stated rate noted within these contracts. ? A payment in the amount of $96,266 was made to the janitorial company utilized by the School District to provide bonuses to janitorial contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private janitorial company. Per review of the contract in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon price. Therefore, expenditures totaling $116,610 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $116,610 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process; however, they were not aware that contract amendments should be initiated prior to the expenditure of funds in this manner. Effect or Potential Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing and employee compensation policies and procedures. Views of Responsible Officials: We concur with this finding. FA 2022-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $116,610 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to the coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $20,854,735 were expended and reported on the Hall County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 202.403 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed the following deficiencies: ? Bonuses totaling $20,344 were paid to individuals who were not employees of the School District. These individuals were hired to perform specific functions as detailed within the associated contracts and were paid amounts in excess of the stated rate noted within these contracts. ? A payment in the amount of $96,266 was made to the janitorial company utilized by the School District to provide bonuses to janitorial contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private janitorial company. Per review of the contract in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon price. Therefore, expenditures totaling $116,610 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $116,610 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process; however, they were not aware that contract amendments should be initiated prior to the expenditure of funds in this manner. Effect or Potential Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing and employee compensation policies and procedures. Views of Responsible Officials: We concur with this finding. FA 2022-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $116,610 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to the coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $20,854,735 were expended and reported on the Hall County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 202.403 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed the following deficiencies: ? Bonuses totaling $20,344 were paid to individuals who were not employees of the School District. These individuals were hired to perform specific functions as detailed within the associated contracts and were paid amounts in excess of the stated rate noted within these contracts. ? A payment in the amount of $96,266 was made to the janitorial company utilized by the School District to provide bonuses to janitorial contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private janitorial company. Per review of the contract in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon price. Therefore, expenditures totaling $116,610 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $116,610 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process; however, they were not aware that contract amendments should be initiated prior to the expenditure of funds in this manner. Effect or Potential Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing and employee compensation policies and procedures. Views of Responsible Officials: We concur with this finding.

FY End: 2022-06-30
Hall County Board of Education
Compliance Requirement: ABI
FA 2022-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund C...

FA 2022-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $116,610 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to the coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $20,854,735 were expended and reported on the Hall County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 202.403 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed the following deficiencies: ? Bonuses totaling $20,344 were paid to individuals who were not employees of the School District. These individuals were hired to perform specific functions as detailed within the associated contracts and were paid amounts in excess of the stated rate noted within these contracts. ? A payment in the amount of $96,266 was made to the janitorial company utilized by the School District to provide bonuses to janitorial contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private janitorial company. Per review of the contract in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon price. Therefore, expenditures totaling $116,610 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $116,610 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process; however, they were not aware that contract amendments should be initiated prior to the expenditure of funds in this manner. Effect or Potential Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing and employee compensation policies and procedures. Views of Responsible Officials: We concur with this finding. FA 2022-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $116,610 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to the coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $20,854,735 were expended and reported on the Hall County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 202.403 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed the following deficiencies: ? Bonuses totaling $20,344 were paid to individuals who were not employees of the School District. These individuals were hired to perform specific functions as detailed within the associated contracts and were paid amounts in excess of the stated rate noted within these contracts. ? A payment in the amount of $96,266 was made to the janitorial company utilized by the School District to provide bonuses to janitorial contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private janitorial company. Per review of the contract in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon price. Therefore, expenditures totaling $116,610 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $116,610 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process; however, they were not aware that contract amendments should be initiated prior to the expenditure of funds in this manner. Effect or Potential Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing and employee compensation policies and procedures. Views of Responsible Officials: We concur with this finding. FA 2022-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $116,610 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to the coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $20,854,735 were expended and reported on the Hall County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 202.403 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed the following deficiencies: ? Bonuses totaling $20,344 were paid to individuals who were not employees of the School District. These individuals were hired to perform specific functions as detailed within the associated contracts and were paid amounts in excess of the stated rate noted within these contracts. ? A payment in the amount of $96,266 was made to the janitorial company utilized by the School District to provide bonuses to janitorial contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private janitorial company. Per review of the contract in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon price. Therefore, expenditures totaling $116,610 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $116,610 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process; however, they were not aware that contract amendments should be initiated prior to the expenditure of funds in this manner. Effect or Potential Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing and employee compensation policies and procedures. Views of Responsible Officials: We concur with this finding.

FY End: 2022-06-30
Hall County Board of Education
Compliance Requirement: ABI
FA 2022-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund C...

FA 2022-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $116,610 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to the coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $20,854,735 were expended and reported on the Hall County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 202.403 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed the following deficiencies: ? Bonuses totaling $20,344 were paid to individuals who were not employees of the School District. These individuals were hired to perform specific functions as detailed within the associated contracts and were paid amounts in excess of the stated rate noted within these contracts. ? A payment in the amount of $96,266 was made to the janitorial company utilized by the School District to provide bonuses to janitorial contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private janitorial company. Per review of the contract in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon price. Therefore, expenditures totaling $116,610 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $116,610 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process; however, they were not aware that contract amendments should be initiated prior to the expenditure of funds in this manner. Effect or Potential Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing and employee compensation policies and procedures. Views of Responsible Officials: We concur with this finding. FA 2022-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $116,610 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to the coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $20,854,735 were expended and reported on the Hall County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 202.403 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed the following deficiencies: ? Bonuses totaling $20,344 were paid to individuals who were not employees of the School District. These individuals were hired to perform specific functions as detailed within the associated contracts and were paid amounts in excess of the stated rate noted within these contracts. ? A payment in the amount of $96,266 was made to the janitorial company utilized by the School District to provide bonuses to janitorial contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private janitorial company. Per review of the contract in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon price. Therefore, expenditures totaling $116,610 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $116,610 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process; however, they were not aware that contract amendments should be initiated prior to the expenditure of funds in this manner. Effect or Potential Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing and employee compensation policies and procedures. Views of Responsible Officials: We concur with this finding. FA 2022-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $116,610 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to the coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $20,854,735 were expended and reported on the Hall County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 202.403 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed the following deficiencies: ? Bonuses totaling $20,344 were paid to individuals who were not employees of the School District. These individuals were hired to perform specific functions as detailed within the associated contracts and were paid amounts in excess of the stated rate noted within these contracts. ? A payment in the amount of $96,266 was made to the janitorial company utilized by the School District to provide bonuses to janitorial contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private janitorial company. Per review of the contract in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon price. Therefore, expenditures totaling $116,610 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $116,610 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process; however, they were not aware that contract amendments should be initiated prior to the expenditure of funds in this manner. Effect or Potential Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing and employee compensation policies and procedures. Views of Responsible Officials: We concur with this finding.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

FY End: 2022-06-30
Saint Louis University
Compliance Requirement: H
Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. D...

Finding 2022 004 Federal Program Title ? Research & Development Cluster Assistance Listing Nos. ? As listed on the Schedule of Expenditures of Federal Awards Federal Agencies ? U.S. Department of Agriculture, U.S. Department of Commerce, U.S. Department of Defense, U.S. Department of Interior, U.S. Department of Justice, Department of State, U.S. Department of Transportation, National Aeronautics and Space Administration, National Endowment for the Humanities, National Science Foundation, U.S. Department of Veterans Affairs, U.S. Department of Energy, U.S. Department of Education, and U.S. Department of Health and Human Services Federal Award Numbers ? As listed on the Schedule of Expenditures of Federal Awards Grant Award Periods ? Various Compliance Requirement ? Period of Performance Criteria: As set forth in 2 CFR Section 200.403, the University may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Additionally, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: While performing period of performance procedures specific to the population of grants with period ending dates during the University?s fiscal year ended June 30, 2022, we noted five grants (with expenditures totaling $9,335) of sixty sampled (with expenditures totaling $76,419) where the expenditure incurred date was after the end of the period of performance and expenditures were still being recorded that were incurred up to 120 days past the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table The periods of performance ended during fiscal year 2022 was one-hundred and five grants. Additionally, while performing period of performance procedures specific to adjustments (including cost transfers) made during the University?s fiscal year ended June 30, 2022, we noted nine cost transfers (totaling $27,865) of sixty sampled (totaling $3,153,441) where the expenditure incurred date was after the end of the period of performance for the following awards: See Schedule of Findings and Questioned Costs for chart/table Positive cost transfers of approximately $4,060,000 and negative cost transfers of $3,510,000 were made during the fiscal year ended June 30, 2022. The University did not have an effective system of internal control in place to ensure costs were not recorded to federal grants beyond the end date of the award?s period of performance. Questioned Cost: Questioned costs are not determinable. Cause and Effect: In discussing these conditions with University management, they stated there was a missing automated control in Workday which would prevent expenditures from being charged to the grant after the period of performance end date. The lack of an automated control contributed to the noncompliance with the period of performance compliance requirement. Repeat Finding: A similar finding was reported in prior year audit as finding number 2021 004. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendations: We recommend the University take a fresh look at the existing policies, procedures and internal controls to ensure costs charged to federal awards are within the period of performance. We recommend the University consider implementing an automated control within Workday that prevents the recording/posting of transactions within a specified timeframe after the end of each grants period of performance. Additionally, we recommend the University consider its existing policies and processes around the automatic posting of payroll charges and consider additional internal controls that would prevent payroll charges from being charged beyond the end date of the award?s period of performance.

« 1 188 189 191 192 210 »