Federal Agencies: Department of the Treasury Federal Assistance Listing Numbers: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Programs: 21.027 Award/Pass-Through Entity Identifying Numbers: HCS-23-AR-2111-018, ARPA - HCS-22-AR-2104-018, COVID-19 - EL-22-AR-27-018, ARPA - EL-22-AR-35-018(1), ARPA - EL-21-AR-03-018(4), ARPA - EL-21-AR-04-018(5), ARPA - EL-22-AR-29-018(2), ARPA - HS-21-AR-01-018(2), BH-22-AR-02-018(1), HCS-23-67-2301-018, HCS-23-AR-2107-018, ARP – 19911, CRF-2024-01, Agreement, 3733, COVID-19 – Agreement, K501, K4893, K4786, K4560, K4862 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Organization allocated payroll expenditures using timecards that were not fully reviewed and approved. Two out of 43 selections for the Coronavirus State and Local Fiscal Recovery Funds program did not have employee and/or supervisor approvals. Cause: The Organization did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed. Effect or Potential Effect: Without adequate controls to ensure that costs allocated to federal programs are supported, the Organization could incorrectly charge expenditures to the federal program. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Organization’s compliance with specified requirements not using a statistically valid sample. Payroll costs charged to the Coronavirus State and Local Fiscal Recovery Funds program were $1,320,137 in fiscal year 2024. Any costs not adequately supported by approved timesheet or subsequent attestation are considered questioned costs. Identification as a Repeat Finding: No similar finding noted in the prior year. Recommendation: The Organization should consistently obtain and retain timesheet approvals from both employees and supervisors for each pay period requested for reimbursement. Subsequent attestations of time worked should be timely obtained if detective controls identify missing timesheet approvals. Views of Responsible Officials: Management agrees with the finding. Management is updating and implementing mitigating controls to ensure approvals are sufficiently documented.
Federal Agencies: Department of the Treasury Federal Assistance Listing Numbers: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Programs: 21.027 Award/Pass-Through Entity Identifying Numbers: HCS-23-AR-2111-018, ARPA - HCS-22-AR-2104-018, COVID-19 - EL-22-AR-27-018, ARPA - EL-22-AR-35-018(1), ARPA - EL-21-AR-03-018(4), ARPA - EL-21-AR-04-018(5), ARPA - EL-22-AR-29-018(2), ARPA - HS-21-AR-01-018(2), BH-22-AR-02-018(1), HCS-23-67-2301-018, HCS-23-AR-2107-018, ARP – 19911, CRF-2024-01, Agreement, 3733, COVID-19 – Agreement, K501, K4893, K4786, K4560, K4862 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Organization allocated payroll expenditures using timecards that were not fully reviewed and approved. Two out of 43 selections for the Coronavirus State and Local Fiscal Recovery Funds program did not have employee and/or supervisor approvals. Cause: The Organization did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed. Effect or Potential Effect: Without adequate controls to ensure that costs allocated to federal programs are supported, the Organization could incorrectly charge expenditures to the federal program. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Organization’s compliance with specified requirements not using a statistically valid sample. Payroll costs charged to the Coronavirus State and Local Fiscal Recovery Funds program were $1,320,137 in fiscal year 2024. Any costs not adequately supported by approved timesheet or subsequent attestation are considered questioned costs. Identification as a Repeat Finding: No similar finding noted in the prior year. Recommendation: The Organization should consistently obtain and retain timesheet approvals from both employees and supervisors for each pay period requested for reimbursement. Subsequent attestations of time worked should be timely obtained if detective controls identify missing timesheet approvals. Views of Responsible Officials: Management agrees with the finding. Management is updating and implementing mitigating controls to ensure approvals are sufficiently documented.
Federal Agencies: Department of the Treasury Federal Assistance Listing Numbers: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Programs: 21.027 Award/Pass-Through Entity Identifying Numbers: HCS-23-AR-2111-018, ARPA - HCS-22-AR-2104-018, COVID-19 - EL-22-AR-27-018, ARPA - EL-22-AR-35-018(1), ARPA - EL-21-AR-03-018(4), ARPA - EL-21-AR-04-018(5), ARPA - EL-22-AR-29-018(2), ARPA - HS-21-AR-01-018(2), BH-22-AR-02-018(1), HCS-23-67-2301-018, HCS-23-AR-2107-018, ARP – 19911, CRF-2024-01, Agreement, 3733, COVID-19 – Agreement, K501, K4893, K4786, K4560, K4862 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Organization allocated payroll expenditures using timecards that were not fully reviewed and approved. Two out of 43 selections for the Coronavirus State and Local Fiscal Recovery Funds program did not have employee and/or supervisor approvals. Cause: The Organization did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed. Effect or Potential Effect: Without adequate controls to ensure that costs allocated to federal programs are supported, the Organization could incorrectly charge expenditures to the federal program. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Organization’s compliance with specified requirements not using a statistically valid sample. Payroll costs charged to the Coronavirus State and Local Fiscal Recovery Funds program were $1,320,137 in fiscal year 2024. Any costs not adequately supported by approved timesheet or subsequent attestation are considered questioned costs. Identification as a Repeat Finding: No similar finding noted in the prior year. Recommendation: The Organization should consistently obtain and retain timesheet approvals from both employees and supervisors for each pay period requested for reimbursement. Subsequent attestations of time worked should be timely obtained if detective controls identify missing timesheet approvals. Views of Responsible Officials: Management agrees with the finding. Management is updating and implementing mitigating controls to ensure approvals are sufficiently documented.
Federal Agencies: Department of the Treasury Federal Assistance Listing Numbers: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Programs: 21.027 Award/Pass-Through Entity Identifying Numbers: HCS-23-AR-2111-018, ARPA - HCS-22-AR-2104-018, COVID-19 - EL-22-AR-27-018, ARPA - EL-22-AR-35-018(1), ARPA - EL-21-AR-03-018(4), ARPA - EL-21-AR-04-018(5), ARPA - EL-22-AR-29-018(2), ARPA - HS-21-AR-01-018(2), BH-22-AR-02-018(1), HCS-23-67-2301-018, HCS-23-AR-2107-018, ARP – 19911, CRF-2024-01, Agreement, 3733, COVID-19 – Agreement, K501, K4893, K4786, K4560, K4862 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Organization allocated payroll expenditures using timecards that were not fully reviewed and approved. Two out of 43 selections for the Coronavirus State and Local Fiscal Recovery Funds program did not have employee and/or supervisor approvals. Cause: The Organization did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed. Effect or Potential Effect: Without adequate controls to ensure that costs allocated to federal programs are supported, the Organization could incorrectly charge expenditures to the federal program. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Organization’s compliance with specified requirements not using a statistically valid sample. Payroll costs charged to the Coronavirus State and Local Fiscal Recovery Funds program were $1,320,137 in fiscal year 2024. Any costs not adequately supported by approved timesheet or subsequent attestation are considered questioned costs. Identification as a Repeat Finding: No similar finding noted in the prior year. Recommendation: The Organization should consistently obtain and retain timesheet approvals from both employees and supervisors for each pay period requested for reimbursement. Subsequent attestations of time worked should be timely obtained if detective controls identify missing timesheet approvals. Views of Responsible Officials: Management agrees with the finding. Management is updating and implementing mitigating controls to ensure approvals are sufficiently documented.
Federal Agencies: Department of the Treasury Federal Assistance Listing Numbers: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Programs: 21.027 Award/Pass-Through Entity Identifying Numbers: HCS-23-AR-2111-018, ARPA - HCS-22-AR-2104-018, COVID-19 - EL-22-AR-27-018, ARPA - EL-22-AR-35-018(1), ARPA - EL-21-AR-03-018(4), ARPA - EL-21-AR-04-018(5), ARPA - EL-22-AR-29-018(2), ARPA - HS-21-AR-01-018(2), BH-22-AR-02-018(1), HCS-23-67-2301-018, HCS-23-AR-2107-018, ARP – 19911, CRF-2024-01, Agreement, 3733, COVID-19 – Agreement, K501, K4893, K4786, K4560, K4862 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Organization allocated payroll expenditures using timecards that were not fully reviewed and approved. Two out of 43 selections for the Coronavirus State and Local Fiscal Recovery Funds program did not have employee and/or supervisor approvals. Cause: The Organization did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed. Effect or Potential Effect: Without adequate controls to ensure that costs allocated to federal programs are supported, the Organization could incorrectly charge expenditures to the federal program. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Organization’s compliance with specified requirements not using a statistically valid sample. Payroll costs charged to the Coronavirus State and Local Fiscal Recovery Funds program were $1,320,137 in fiscal year 2024. Any costs not adequately supported by approved timesheet or subsequent attestation are considered questioned costs. Identification as a Repeat Finding: No similar finding noted in the prior year. Recommendation: The Organization should consistently obtain and retain timesheet approvals from both employees and supervisors for each pay period requested for reimbursement. Subsequent attestations of time worked should be timely obtained if detective controls identify missing timesheet approvals. Views of Responsible Officials: Management agrees with the finding. Management is updating and implementing mitigating controls to ensure approvals are sufficiently documented.
Federal Agencies: Department of the Treasury Federal Assistance Listing Numbers: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Programs: 21.027 Award/Pass-Through Entity Identifying Numbers: HCS-23-AR-2111-018, ARPA - HCS-22-AR-2104-018, COVID-19 - EL-22-AR-27-018, ARPA - EL-22-AR-35-018(1), ARPA - EL-21-AR-03-018(4), ARPA - EL-21-AR-04-018(5), ARPA - EL-22-AR-29-018(2), ARPA - HS-21-AR-01-018(2), BH-22-AR-02-018(1), HCS-23-67-2301-018, HCS-23-AR-2107-018, ARP – 19911, CRF-2024-01, Agreement, 3733, COVID-19 – Agreement, K501, K4893, K4786, K4560, K4862 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Organization allocated payroll expenditures using timecards that were not fully reviewed and approved. Two out of 43 selections for the Coronavirus State and Local Fiscal Recovery Funds program did not have employee and/or supervisor approvals. Cause: The Organization did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed. Effect or Potential Effect: Without adequate controls to ensure that costs allocated to federal programs are supported, the Organization could incorrectly charge expenditures to the federal program. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Organization’s compliance with specified requirements not using a statistically valid sample. Payroll costs charged to the Coronavirus State and Local Fiscal Recovery Funds program were $1,320,137 in fiscal year 2024. Any costs not adequately supported by approved timesheet or subsequent attestation are considered questioned costs. Identification as a Repeat Finding: No similar finding noted in the prior year. Recommendation: The Organization should consistently obtain and retain timesheet approvals from both employees and supervisors for each pay period requested for reimbursement. Subsequent attestations of time worked should be timely obtained if detective controls identify missing timesheet approvals. Views of Responsible Officials: Management agrees with the finding. Management is updating and implementing mitigating controls to ensure approvals are sufficiently documented.
Federal Agencies: Department of the Treasury Federal Assistance Listing Numbers: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Programs: 21.027 Award/Pass-Through Entity Identifying Numbers: HCS-23-AR-2111-018, ARPA - HCS-22-AR-2104-018, COVID-19 - EL-22-AR-27-018, ARPA - EL-22-AR-35-018(1), ARPA - EL-21-AR-03-018(4), ARPA - EL-21-AR-04-018(5), ARPA - EL-22-AR-29-018(2), ARPA - HS-21-AR-01-018(2), BH-22-AR-02-018(1), HCS-23-67-2301-018, HCS-23-AR-2107-018, ARP – 19911, CRF-2024-01, Agreement, 3733, COVID-19 – Agreement, K501, K4893, K4786, K4560, K4862 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Organization allocated payroll expenditures using timecards that were not fully reviewed and approved. Two out of 43 selections for the Coronavirus State and Local Fiscal Recovery Funds program did not have employee and/or supervisor approvals. Cause: The Organization did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed. Effect or Potential Effect: Without adequate controls to ensure that costs allocated to federal programs are supported, the Organization could incorrectly charge expenditures to the federal program. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Organization’s compliance with specified requirements not using a statistically valid sample. Payroll costs charged to the Coronavirus State and Local Fiscal Recovery Funds program were $1,320,137 in fiscal year 2024. Any costs not adequately supported by approved timesheet or subsequent attestation are considered questioned costs. Identification as a Repeat Finding: No similar finding noted in the prior year. Recommendation: The Organization should consistently obtain and retain timesheet approvals from both employees and supervisors for each pay period requested for reimbursement. Subsequent attestations of time worked should be timely obtained if detective controls identify missing timesheet approvals. Views of Responsible Officials: Management agrees with the finding. Management is updating and implementing mitigating controls to ensure approvals are sufficiently documented.
Federal Agencies: Department of the Treasury Federal Assistance Listing Numbers: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Programs: 21.027 Award/Pass-Through Entity Identifying Numbers: HCS-23-AR-2111-018, ARPA - HCS-22-AR-2104-018, COVID-19 - EL-22-AR-27-018, ARPA - EL-22-AR-35-018(1), ARPA - EL-21-AR-03-018(4), ARPA - EL-21-AR-04-018(5), ARPA - EL-22-AR-29-018(2), ARPA - HS-21-AR-01-018(2), BH-22-AR-02-018(1), HCS-23-67-2301-018, HCS-23-AR-2107-018, ARP – 19911, CRF-2024-01, Agreement, 3733, COVID-19 – Agreement, K501, K4893, K4786, K4560, K4862 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Organization allocated payroll expenditures using timecards that were not fully reviewed and approved. Two out of 43 selections for the Coronavirus State and Local Fiscal Recovery Funds program did not have employee and/or supervisor approvals. Cause: The Organization did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed. Effect or Potential Effect: Without adequate controls to ensure that costs allocated to federal programs are supported, the Organization could incorrectly charge expenditures to the federal program. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Organization’s compliance with specified requirements not using a statistically valid sample. Payroll costs charged to the Coronavirus State and Local Fiscal Recovery Funds program were $1,320,137 in fiscal year 2024. Any costs not adequately supported by approved timesheet or subsequent attestation are considered questioned costs. Identification as a Repeat Finding: No similar finding noted in the prior year. Recommendation: The Organization should consistently obtain and retain timesheet approvals from both employees and supervisors for each pay period requested for reimbursement. Subsequent attestations of time worked should be timely obtained if detective controls identify missing timesheet approvals. Views of Responsible Officials: Management agrees with the finding. Management is updating and implementing mitigating controls to ensure approvals are sufficiently documented.
Federal Agencies: Department of the Treasury Federal Assistance Listing Numbers: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Programs: 21.027 Award/Pass-Through Entity Identifying Numbers: HCS-23-AR-2111-018, ARPA - HCS-22-AR-2104-018, COVID-19 - EL-22-AR-27-018, ARPA - EL-22-AR-35-018(1), ARPA - EL-21-AR-03-018(4), ARPA - EL-21-AR-04-018(5), ARPA - EL-22-AR-29-018(2), ARPA - HS-21-AR-01-018(2), BH-22-AR-02-018(1), HCS-23-67-2301-018, HCS-23-AR-2107-018, ARP – 19911, CRF-2024-01, Agreement, 3733, COVID-19 – Agreement, K501, K4893, K4786, K4560, K4862 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Organization allocated payroll expenditures using timecards that were not fully reviewed and approved. Two out of 43 selections for the Coronavirus State and Local Fiscal Recovery Funds program did not have employee and/or supervisor approvals. Cause: The Organization did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed. Effect or Potential Effect: Without adequate controls to ensure that costs allocated to federal programs are supported, the Organization could incorrectly charge expenditures to the federal program. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Organization’s compliance with specified requirements not using a statistically valid sample. Payroll costs charged to the Coronavirus State and Local Fiscal Recovery Funds program were $1,320,137 in fiscal year 2024. Any costs not adequately supported by approved timesheet or subsequent attestation are considered questioned costs. Identification as a Repeat Finding: No similar finding noted in the prior year. Recommendation: The Organization should consistently obtain and retain timesheet approvals from both employees and supervisors for each pay period requested for reimbursement. Subsequent attestations of time worked should be timely obtained if detective controls identify missing timesheet approvals. Views of Responsible Officials: Management agrees with the finding. Management is updating and implementing mitigating controls to ensure approvals are sufficiently documented.
Federal Agencies: Department of the Treasury Federal Assistance Listing Numbers: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Programs: 21.027 Award/Pass-Through Entity Identifying Numbers: HCS-23-AR-2111-018, ARPA - HCS-22-AR-2104-018, COVID-19 - EL-22-AR-27-018, ARPA - EL-22-AR-35-018(1), ARPA - EL-21-AR-03-018(4), ARPA - EL-21-AR-04-018(5), ARPA - EL-22-AR-29-018(2), ARPA - HS-21-AR-01-018(2), BH-22-AR-02-018(1), HCS-23-67-2301-018, HCS-23-AR-2107-018, ARP – 19911, CRF-2024-01, Agreement, 3733, COVID-19 – Agreement, K501, K4893, K4786, K4560, K4862 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Organization allocated payroll expenditures using timecards that were not fully reviewed and approved. Two out of 43 selections for the Coronavirus State and Local Fiscal Recovery Funds program did not have employee and/or supervisor approvals. Cause: The Organization did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed. Effect or Potential Effect: Without adequate controls to ensure that costs allocated to federal programs are supported, the Organization could incorrectly charge expenditures to the federal program. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Organization’s compliance with specified requirements not using a statistically valid sample. Payroll costs charged to the Coronavirus State and Local Fiscal Recovery Funds program were $1,320,137 in fiscal year 2024. Any costs not adequately supported by approved timesheet or subsequent attestation are considered questioned costs. Identification as a Repeat Finding: No similar finding noted in the prior year. Recommendation: The Organization should consistently obtain and retain timesheet approvals from both employees and supervisors for each pay period requested for reimbursement. Subsequent attestations of time worked should be timely obtained if detective controls identify missing timesheet approvals. Views of Responsible Officials: Management agrees with the finding. Management is updating and implementing mitigating controls to ensure approvals are sufficiently documented.
Federal Agencies: Department of the Treasury Federal Assistance Listing Numbers: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Programs: 21.027 Award/Pass-Through Entity Identifying Numbers: HCS-23-AR-2111-018, ARPA - HCS-22-AR-2104-018, COVID-19 - EL-22-AR-27-018, ARPA - EL-22-AR-35-018(1), ARPA - EL-21-AR-03-018(4), ARPA - EL-21-AR-04-018(5), ARPA - EL-22-AR-29-018(2), ARPA - HS-21-AR-01-018(2), BH-22-AR-02-018(1), HCS-23-67-2301-018, HCS-23-AR-2107-018, ARP – 19911, CRF-2024-01, Agreement, 3733, COVID-19 – Agreement, K501, K4893, K4786, K4560, K4862 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Organization allocated payroll expenditures using timecards that were not fully reviewed and approved. Two out of 43 selections for the Coronavirus State and Local Fiscal Recovery Funds program did not have employee and/or supervisor approvals. Cause: The Organization did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed. Effect or Potential Effect: Without adequate controls to ensure that costs allocated to federal programs are supported, the Organization could incorrectly charge expenditures to the federal program. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Organization’s compliance with specified requirements not using a statistically valid sample. Payroll costs charged to the Coronavirus State and Local Fiscal Recovery Funds program were $1,320,137 in fiscal year 2024. Any costs not adequately supported by approved timesheet or subsequent attestation are considered questioned costs. Identification as a Repeat Finding: No similar finding noted in the prior year. Recommendation: The Organization should consistently obtain and retain timesheet approvals from both employees and supervisors for each pay period requested for reimbursement. Subsequent attestations of time worked should be timely obtained if detective controls identify missing timesheet approvals. Views of Responsible Officials: Management agrees with the finding. Management is updating and implementing mitigating controls to ensure approvals are sufficiently documented.
Federal Agencies: Department of the Treasury Federal Assistance Listing Numbers: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Programs: 21.027 Award/Pass-Through Entity Identifying Numbers: HCS-23-AR-2111-018, ARPA - HCS-22-AR-2104-018, COVID-19 - EL-22-AR-27-018, ARPA - EL-22-AR-35-018(1), ARPA - EL-21-AR-03-018(4), ARPA - EL-21-AR-04-018(5), ARPA - EL-22-AR-29-018(2), ARPA - HS-21-AR-01-018(2), BH-22-AR-02-018(1), HCS-23-67-2301-018, HCS-23-AR-2107-018, ARP – 19911, CRF-2024-01, Agreement, 3733, COVID-19 – Agreement, K501, K4893, K4786, K4560, K4862 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation – Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that the Organization allocated payroll expenditures using timecards that were not fully reviewed and approved. Two out of 43 selections for the Coronavirus State and Local Fiscal Recovery Funds program did not have employee and/or supervisor approvals. Cause: The Organization did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed. Effect or Potential Effect: Without adequate controls to ensure that costs allocated to federal programs are supported, the Organization could incorrectly charge expenditures to the federal program. Questioned Costs: None above the $25,000 reporting threshold. Context: This is a condition identified per review of the Organization’s compliance with specified requirements not using a statistically valid sample. Payroll costs charged to the Coronavirus State and Local Fiscal Recovery Funds program were $1,320,137 in fiscal year 2024. Any costs not adequately supported by approved timesheet or subsequent attestation are considered questioned costs. Identification as a Repeat Finding: No similar finding noted in the prior year. Recommendation: The Organization should consistently obtain and retain timesheet approvals from both employees and supervisors for each pay period requested for reimbursement. Subsequent attestations of time worked should be timely obtained if detective controls identify missing timesheet approvals. Views of Responsible Officials: Management agrees with the finding. Management is updating and implementing mitigating controls to ensure approvals are sufficiently documented.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.