2 CFR 200 § 200.403

Findings Citing § 200.403

Factors affecting allowability of costs.

Total Findings
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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.
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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.

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
Winslow Residential Hall, Inc.
Compliance Requirement: AB
Finding Number: 2022-001 Repeat Finding: Yes, 2021-002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A19AV00933 N/A Education Stabilization Fund 84.425 A19AV00933 N/A Federal Agency: U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles CRI...

Finding Number: 2022-001 Repeat Finding: Yes, 2021-002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A19AV00933 N/A Education Stabilization Fund 84.425 A19AV00933 N/A Federal Agency: U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles CRITERIA Hall management is responsible for establishing and maintaining internal controls over disbursements that are adequate to ensure all financial activities are properly processed and reported. Additionally, the Hall is required, except where otherwise authorized by statute, to ensure costs meet the general criteria outlined in 2 CFR 200.403 in order to be allowable under federal awards, including the costs be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles. Indian tribes and tribal organizations may without the approval of the BIA expend funds provided under a self-determination contract for purposes identified in 25 USC 46, to the extent that the expenditure of the funds is supportive of a contracted program (USC 46). These guidelines require internal controls over expenditures, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines. (25 CFR 39; 25 CFR 900). Indian tribes and tribal organizations may, without the approval of the Bureau of Indian Affairs (BIA), expend funds provided under a self-determination contract for purposes identified in 25?SC 450j-l(k), to the extent that the expenditure of the funds is supportive of a contracted program?25 USC 450j-l(k)). These guidelines require internal controls over expenditures of federal monies, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines (25 CFR 39; 25 CFR 45; 25 CFR 900). CONDITION The Hall did not follow its Board adopted policies for federal regulations regarding disbursements and payroll to ensure all financial activities were properly processed, recorded in the appropriate fiscal year, and supported. CAUSE The Hall has not always implemented and followed controls over disbursement and payroll transactions. EFFECT The Hall was not in compliance with Board adopted policies for federal regulations and guidelines. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. The following items were noted during our review of disbursement transactions: ? For one of 10 travel reimbursements reviewed, adequate backup was not retained to support the reimbursement. ? For one of 10 travel reimbursements reviewed, there was an overpayment of $33. ? For two of 45 disbursements reviewed, the goods or services were received prior to the issuance and approval of the purchase order. ? For two of 45 disbursements reviewed and two of 14 disbursements reviewed for cutoff, there was no receiving report received; therefore could not be determined if the goods or services were received prior to payment. ? For five of 14 cutoff selections reviewed, the expenditure was recorded in the fiscal year 2023 but should have been in fiscal year 2022. Audit adjustments were required to properly report the financial statements. ? For five of 45 disbursements reviewed, the goods or services were received after the payment was made. ? For one of 45 disbursements reviewed, the quantity on the receiving report did not match the purchase order. ? For one of 40 employee payrolls reviewed, the employee received backpay, but the Hall was unable to provide supporting documentation for the backpay. ? The Department of Treasury guidelines for using ARPA funds for hazard pay at a limit of $25,000 per employee. The Hall had three employees who exceeded this limit during the 2022 fiscal year. ? The Hall had a current year overexpenditure in the Education Stabilization Fund grant by $48,608. ? For one of 40 employee payrolls reviewed, the employee was overpaid by $160.55. RECOMMENDATION The Hall should adhere to its Board adopted policies and federal regulations and ensure all transactions are supported. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

FY End: 2022-06-30
Winslow Residential Hall, Inc.
Compliance Requirement: AB
Finding Number: 2022-001 Repeat Finding: Yes, 2021-002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A19AV00933 N/A Education Stabilization Fund 84.425 A19AV00933 N/A Federal Agency: U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles CRI...

Finding Number: 2022-001 Repeat Finding: Yes, 2021-002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A19AV00933 N/A Education Stabilization Fund 84.425 A19AV00933 N/A Federal Agency: U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles CRITERIA Hall management is responsible for establishing and maintaining internal controls over disbursements that are adequate to ensure all financial activities are properly processed and reported. Additionally, the Hall is required, except where otherwise authorized by statute, to ensure costs meet the general criteria outlined in 2 CFR 200.403 in order to be allowable under federal awards, including the costs be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles. Indian tribes and tribal organizations may without the approval of the BIA expend funds provided under a self-determination contract for purposes identified in 25 USC 46, to the extent that the expenditure of the funds is supportive of a contracted program (USC 46). These guidelines require internal controls over expenditures, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines. (25 CFR 39; 25 CFR 900). Indian tribes and tribal organizations may, without the approval of the Bureau of Indian Affairs (BIA), expend funds provided under a self-determination contract for purposes identified in 25?SC 450j-l(k), to the extent that the expenditure of the funds is supportive of a contracted program?25 USC 450j-l(k)). These guidelines require internal controls over expenditures of federal monies, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines (25 CFR 39; 25 CFR 45; 25 CFR 900). CONDITION The Hall did not follow its Board adopted policies for federal regulations regarding disbursements and payroll to ensure all financial activities were properly processed, recorded in the appropriate fiscal year, and supported. CAUSE The Hall has not always implemented and followed controls over disbursement and payroll transactions. EFFECT The Hall was not in compliance with Board adopted policies for federal regulations and guidelines. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. The following items were noted during our review of disbursement transactions: ? For one of 10 travel reimbursements reviewed, adequate backup was not retained to support the reimbursement. ? For one of 10 travel reimbursements reviewed, there was an overpayment of $33. ? For two of 45 disbursements reviewed, the goods or services were received prior to the issuance and approval of the purchase order. ? For two of 45 disbursements reviewed and two of 14 disbursements reviewed for cutoff, there was no receiving report received; therefore could not be determined if the goods or services were received prior to payment. ? For five of 14 cutoff selections reviewed, the expenditure was recorded in the fiscal year 2023 but should have been in fiscal year 2022. Audit adjustments were required to properly report the financial statements. ? For five of 45 disbursements reviewed, the goods or services were received after the payment was made. ? For one of 45 disbursements reviewed, the quantity on the receiving report did not match the purchase order. ? For one of 40 employee payrolls reviewed, the employee received backpay, but the Hall was unable to provide supporting documentation for the backpay. ? The Department of Treasury guidelines for using ARPA funds for hazard pay at a limit of $25,000 per employee. The Hall had three employees who exceeded this limit during the 2022 fiscal year. ? The Hall had a current year overexpenditure in the Education Stabilization Fund grant by $48,608. ? For one of 40 employee payrolls reviewed, the employee was overpaid by $160.55. RECOMMENDATION The Hall should adhere to its Board adopted policies and federal regulations and ensure all transactions are supported. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

FY End: 2022-06-30
Winslow Residential Hall, Inc.
Compliance Requirement: AB
Finding Number: 2022-001 Repeat Finding: Yes, 2021-002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A19AV00933 N/A Education Stabilization Fund 84.425 A19AV00933 N/A Federal Agency: U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles CRI...

Finding Number: 2022-001 Repeat Finding: Yes, 2021-002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A19AV00933 N/A Education Stabilization Fund 84.425 A19AV00933 N/A Federal Agency: U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles CRITERIA Hall management is responsible for establishing and maintaining internal controls over disbursements that are adequate to ensure all financial activities are properly processed and reported. Additionally, the Hall is required, except where otherwise authorized by statute, to ensure costs meet the general criteria outlined in 2 CFR 200.403 in order to be allowable under federal awards, including the costs be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles. Indian tribes and tribal organizations may without the approval of the BIA expend funds provided under a self-determination contract for purposes identified in 25 USC 46, to the extent that the expenditure of the funds is supportive of a contracted program (USC 46). These guidelines require internal controls over expenditures, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines. (25 CFR 39; 25 CFR 900). Indian tribes and tribal organizations may, without the approval of the Bureau of Indian Affairs (BIA), expend funds provided under a self-determination contract for purposes identified in 25?SC 450j-l(k), to the extent that the expenditure of the funds is supportive of a contracted program?25 USC 450j-l(k)). These guidelines require internal controls over expenditures of federal monies, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines (25 CFR 39; 25 CFR 45; 25 CFR 900). CONDITION The Hall did not follow its Board adopted policies for federal regulations regarding disbursements and payroll to ensure all financial activities were properly processed, recorded in the appropriate fiscal year, and supported. CAUSE The Hall has not always implemented and followed controls over disbursement and payroll transactions. EFFECT The Hall was not in compliance with Board adopted policies for federal regulations and guidelines. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. The following items were noted during our review of disbursement transactions: ? For one of 10 travel reimbursements reviewed, adequate backup was not retained to support the reimbursement. ? For one of 10 travel reimbursements reviewed, there was an overpayment of $33. ? For two of 45 disbursements reviewed, the goods or services were received prior to the issuance and approval of the purchase order. ? For two of 45 disbursements reviewed and two of 14 disbursements reviewed for cutoff, there was no receiving report received; therefore could not be determined if the goods or services were received prior to payment. ? For five of 14 cutoff selections reviewed, the expenditure was recorded in the fiscal year 2023 but should have been in fiscal year 2022. Audit adjustments were required to properly report the financial statements. ? For five of 45 disbursements reviewed, the goods or services were received after the payment was made. ? For one of 45 disbursements reviewed, the quantity on the receiving report did not match the purchase order. ? For one of 40 employee payrolls reviewed, the employee received backpay, but the Hall was unable to provide supporting documentation for the backpay. ? The Department of Treasury guidelines for using ARPA funds for hazard pay at a limit of $25,000 per employee. The Hall had three employees who exceeded this limit during the 2022 fiscal year. ? The Hall had a current year overexpenditure in the Education Stabilization Fund grant by $48,608. ? For one of 40 employee payrolls reviewed, the employee was overpaid by $160.55. RECOMMENDATION The Hall should adhere to its Board adopted policies and federal regulations and ensure all transactions are supported. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

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