Condition/Context: The single audit report was not submitted to the Office of Management and Budget in accordance with the reporting requirement. Criteria: COSO/Internal Control Framework defines control activities as “policies and procedures that help ensure management’s directives are carried out.” This would include preparation of the schedule of expenditures of federal awards and the related data collection form in a timely manner. Uniform Guidance 2 CFR 200.501 states that the audit shall be completed, and the data collection form shall be submitted within the earlier of 30 days after the receipt of the auditor’s report, or 9 months after the end of the audit period. The due date was extended six months as a result of the challenges related to the coronavirus pandemic. Cause: The single audit report was not submitted due to delays in the year-end closing process, resulting in the audit being delayed. Effect: Questioned Costs: None Recommendation: We believe the year-end closing and audit preparation processes should be completed sooner after year end. Progress should be monitored by management to ensure that established due dates are being met and required reports are submitted to regulatory agencies within the compliance time frame. As a result of the finding, the organization did not provide required information to its federal oversight agency in a timely manner.
Condition/Context: The single audit report was not submitted to the Office of Management and Budget in accordance with the reporting requirement. Criteria: COSO/Internal Control Framework defines control activities as “policies and procedures that help ensure management’s directives are carried out.” This would include preparation of the schedule of expenditures of federal awards and the related data collection form in a timely manner. Uniform Guidance 2 CFR 200.501 states that the audit shall be completed, and the data collection form shall be submitted within the earlier of 30 days after the receipt of the auditor’s report, or 9 months after the end of the audit period. The due date was extended six months as a result of the challenges related to the coronavirus pandemic. Cause: The single audit report was not submitted due to delays in the year-end closing process, resulting in the audit being delayed. Effect: Questioned Costs: None Recommendation: We believe the year-end closing and audit preparation processes should be completed sooner after year end. Progress should be monitored by management to ensure that established due dates are being met and required reports are submitted to regulatory agencies within the compliance time frame. As a result of the finding, the organization did not provide required information to its federal oversight agency in a timely manner.
Condition/Context: The single audit report was not submitted to the Office of Management and Budget in accordance with the reporting requirement. Criteria: COSO/Internal Control Framework defines control activities as “policies and procedures that help ensure management’s directives are carried out.” This would include preparation of the schedule of expenditures of federal awards and the related data collection form in a timely manner. Uniform Guidance 2 CFR 200.501 states that the audit shall be completed, and the data collection form shall be submitted within the earlier of 30 days after the receipt of the auditor’s report, or 9 months after the end of the audit period. The due date was extended six months as a result of the challenges related to the coronavirus pandemic. Cause: The single audit report was not submitted due to delays in the year-end closing process, resulting in the audit being delayed. Effect: Questioned Costs: None Recommendation: We believe the year-end closing and audit preparation processes should be completed sooner after year end. Progress should be monitored by management to ensure that established due dates are being met and required reports are submitted to regulatory agencies within the compliance time frame. As a result of the finding, the organization did not provide required information to its federal oversight agency in a timely manner.
Condition/Context: The single audit report was not submitted to the Office of Management and Budget in accordance with the reporting requirement. Criteria: COSO/Internal Control Framework defines control activities as “policies and procedures that help ensure management’s directives are carried out.” This would include preparation of the schedule of expenditures of federal awards and the related data collection form in a timely manner. Uniform Guidance 2 CFR 200.501 states that the audit shall be completed, and the data collection form shall be submitted within the earlier of 30 days after the receipt of the auditor’s report, or 9 months after the end of the audit period. The due date was extended six months as a result of the challenges related to the coronavirus pandemic. Cause: The single audit report was not submitted due to delays in the year-end closing process, resulting in the audit being delayed. Effect: Questioned Costs: None Recommendation: We believe the year-end closing and audit preparation processes should be completed sooner after year end. Progress should be monitored by management to ensure that established due dates are being met and required reports are submitted to regulatory agencies within the compliance time frame. As a result of the finding, the organization did not provide required information to its federal oversight agency in a timely manner.
Finding 2023-004 – Subrecipient Monitoring– Material Weakness and Noncompliance Federal Program: Aging Cluster Federal Agency: U.S. Department of Health and Human Services ALN: 93.044, 93.045, 93.053 (Aging Cluster) Federal Award Number: 2301ALOASS, 2101ALSSC6, 2301ALOACM/2301ALOAHD, 2101ALCMC6/2101ALHDC6 Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.332 provides various requirements for subrecipient monitoring including the following: • 2 CFR 200.332(d) requires pass-through entities to “monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved”. • 2 CFR 200.332(f) requires pass-through entities to “verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501.” Condition: Warren Averett tested eight subrecipients in the Aging Cluster and noted that two were not monitored adequately during the award period and the Commission did not obtain single audit reports for any of the subrecipients tested. Cause: Although the Commission performed certain procedures required by 2 CFR 200.332, the policies and procedures do not contain adequate guidance to fully address the requirements. Effect: The lack of adequate policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is a repeat finding. Questioned Costs: None noted. Recommendation: Warren Averett recommends that the Commission strengthen its documented policies and procedures regarding subrecipient monitoring. View of Responsible Officials: See Corrective Action Plan at the end of the report.
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings