2 CFR 200 § 200.430

Findings Citing § 200.430

Compensation—personal services.

Total Findings
14,291
Across all audits in database
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About this section
Section 200.430 outlines the rules for compensation related to personal services under Federal awards, stating that payments must be reasonable, follow established policies, and comply with applicable laws. It affects organizations receiving Federal funding, ensuring that employee compensation aligns with similar roles in the market and adheres to the recipient's policies.
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FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
The Howard University
Compliance Requirement: B
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 prod...

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.

FY End: 2024-06-30
City of South Portland, Maine
Compliance Requirement: B
2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as suppo...

2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as support for charges to Federal awards. Condition: Time and effort documentation for School Department employees who are allocated amongst multiple Federal grants is based on budgeted estimates. These estimates are not adequate to ensure actual time spent on each grant is charged to the grants. Budgeted estimates are not trued up to reflect actual time worked at year end. Cause: The School Department does not have policies and procedures requiring employees charged to multiple grants, or to Federal and non-Federal activities, to track actual time spent on each grant. There are no policies and procedures to adjust budgeted estimates to actual time incurred for each grant on a periodic basis. Effect: It could not be determined if payroll costs reflected actual time worked on the grant. This could result in grants being allocated a disproportionate share of payroll costs. Recommendation: Personnel activity reports should be prepared at least monthly to document actual time worked on grants. Budgeted payroll allocations should be adjusted periodically to reflect actual time worked. Questioned Costs: None

FY End: 2024-06-30
City of South Portland, Maine
Compliance Requirement: B
2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as suppo...

2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as support for charges to Federal awards. Condition: Time and effort documentation for School Department employees who are allocated amongst multiple Federal grants is based on budgeted estimates. These estimates are not adequate to ensure actual time spent on each grant is charged to the grants. Budgeted estimates are not trued up to reflect actual time worked at year end. Cause: The School Department does not have policies and procedures requiring employees charged to multiple grants, or to Federal and non-Federal activities, to track actual time spent on each grant. There are no policies and procedures to adjust budgeted estimates to actual time incurred for each grant on a periodic basis. Effect: It could not be determined if payroll costs reflected actual time worked on the grant. This could result in grants being allocated a disproportionate share of payroll costs. Recommendation: Personnel activity reports should be prepared at least monthly to document actual time worked on grants. Budgeted payroll allocations should be adjusted periodically to reflect actual time worked. Questioned Costs: None

FY End: 2024-06-30
City of South Portland, Maine
Compliance Requirement: B
2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as suppo...

2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as support for charges to Federal awards. Condition: Time and effort documentation for School Department employees who are allocated amongst multiple Federal grants is based on budgeted estimates. These estimates are not adequate to ensure actual time spent on each grant is charged to the grants. Budgeted estimates are not trued up to reflect actual time worked at year end. Cause: The School Department does not have policies and procedures requiring employees charged to multiple grants, or to Federal and non-Federal activities, to track actual time spent on each grant. There are no policies and procedures to adjust budgeted estimates to actual time incurred for each grant on a periodic basis. Effect: It could not be determined if payroll costs reflected actual time worked on the grant. This could result in grants being allocated a disproportionate share of payroll costs. Recommendation: Personnel activity reports should be prepared at least monthly to document actual time worked on grants. Budgeted payroll allocations should be adjusted periodically to reflect actual time worked. Questioned Costs: None

FY End: 2024-06-30
City of South Portland, Maine
Compliance Requirement: B
2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as suppo...

2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as support for charges to Federal awards. Condition: Time and effort documentation for School Department employees who are allocated amongst multiple Federal grants is based on budgeted estimates. These estimates are not adequate to ensure actual time spent on each grant is charged to the grants. Budgeted estimates are not trued up to reflect actual time worked at year end. Cause: The School Department does not have policies and procedures requiring employees charged to multiple grants, or to Federal and non-Federal activities, to track actual time spent on each grant. There are no policies and procedures to adjust budgeted estimates to actual time incurred for each grant on a periodic basis. Effect: It could not be determined if payroll costs reflected actual time worked on the grant. This could result in grants being allocated a disproportionate share of payroll costs. Recommendation: Personnel activity reports should be prepared at least monthly to document actual time worked on grants. Budgeted payroll allocations should be adjusted periodically to reflect actual time worked. Questioned Costs: None

FY End: 2024-06-30
City of South Portland, Maine
Compliance Requirement: B
2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as suppo...

2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as support for charges to Federal awards. Condition: Time and effort documentation for School Department employees who are allocated amongst multiple Federal grants is based on budgeted estimates. These estimates are not adequate to ensure actual time spent on each grant is charged to the grants. Budgeted estimates are not trued up to reflect actual time worked at year end. Cause: The School Department does not have policies and procedures requiring employees charged to multiple grants, or to Federal and non-Federal activities, to track actual time spent on each grant. There are no policies and procedures to adjust budgeted estimates to actual time incurred for each grant on a periodic basis. Effect: It could not be determined if payroll costs reflected actual time worked on the grant. This could result in grants being allocated a disproportionate share of payroll costs. Recommendation: Personnel activity reports should be prepared at least monthly to document actual time worked on grants. Budgeted payroll allocations should be adjusted periodically to reflect actual time worked. Questioned Costs: None

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