Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. In addition to the procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. 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 PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster Grantor: Department of Health and Human Services and National Aeronautics and Space Administration Award Names: Biomedical Research and Research Training and Science Award Year: July 1, 2022 – June 30, 2023 Award Number: 5R01GM140457-03 and 80NSSC21K0753 Assistance Listing Numbers: 93.859 and 43.001 Pass-through entity: Not applicable 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. 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, the College procedures include (amongst other items) obtaining a Commitment Form from the subrecipient, performing an initial risk assessment on all subrecipients, and updating that risk assessment based on the Controller Office’s judgement. The College also annually reviews the subrecipient's Uniform Guidance (“UG”) report and performs any necessary follow-up to issue a management decision, where applicable. Condition Through our testing of 4 subrecipients, we noted the following: • For all samples, we were unable to obtain sufficient evidence of the College’s annual subrecipient risk assessment. • For all samples, we were unable to obtain sufficient evidence of the College’s annual review of the audited financial statements and UG report, documentation of their review of the subrecipient’s audit report, and actions taken as a result of the findings in the report. Cause The College indicated subrecipient reviews, including the annual risk assessment and review of the UG report, were performed informally by the Principal Investigators and financial staff and not consistently documented. The College cites insufficient staffing needed for the formal documentation of the subrecipient risk assessment and monitoring procedures as the cause. Effect The lack of an annual review of subrecipient UG reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the UG. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs None identified. Recommendation We recommend the College reassess the design of its controls around subrecipient risk assessment and monitoring during the ongoing monitoring process. The College should formalize the documentation and review of its controls related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings.
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster Grantor: Department of Health and Human Services and National Aeronautics and Space Administration Award Names: Biomedical Research and Research Training and Science Award Year: July 1, 2022 – June 30, 2023 Award Number: 5R01GM140457-03 and 80NSSC21K0753 Assistance Listing Numbers: 93.859 and 43.001 Pass-through entity: Not applicable 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. 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, the College procedures include (amongst other items) obtaining a Commitment Form from the subrecipient, performing an initial risk assessment on all subrecipients, and updating that risk assessment based on the Controller Office’s judgement. The College also annually reviews the subrecipient's Uniform Guidance (“UG”) report and performs any necessary follow-up to issue a management decision, where applicable. Condition Through our testing of 4 subrecipients, we noted the following: • For all samples, we were unable to obtain sufficient evidence of the College’s annual subrecipient risk assessment. • For all samples, we were unable to obtain sufficient evidence of the College’s annual review of the audited financial statements and UG report, documentation of their review of the subrecipient’s audit report, and actions taken as a result of the findings in the report. Cause The College indicated subrecipient reviews, including the annual risk assessment and review of the UG report, were performed informally by the Principal Investigators and financial staff and not consistently documented. The College cites insufficient staffing needed for the formal documentation of the subrecipient risk assessment and monitoring procedures as the cause. Effect The lack of an annual review of subrecipient UG reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the UG. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs None identified. Recommendation We recommend the College reassess the design of its controls around subrecipient risk assessment and monitoring during the ongoing monitoring process. The College should formalize the documentation and review of its controls related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings.