Finding 1081219 (2024-001)

Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 93.242 and 93.853, U.S. Department of Health and Human Services - 47.041 and 47.049, National Science Foundation - 84.326, U.S. Department of Education Federal Award Identification Number and Year - Research and Development Cluster: - 93.242 - 5 F31 MH125541-03 - 93.853 - 5 U01 NS120910 02; 1 R61 NS128232-01 - 47.041 - CMMI 2151465; CBET-2125056 EAGER - 47.049 - CHE 1900097; CHE-1955161 - 84.326 - H326T230006-1- FY24-28 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.344, a recipient must liquidate all financial obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the federal award and must have controls in place as part of that liquidation process in order to ensure that all costs charged to the grant were incurred during the period of performance. Condition - The University did not complete full grant closeout procedures in a timely manner for 10 out of 25 grants that were tested with a period of performance that ended in the year ended June 30, 2024. For 2 of those 10, there was not an independent review of the closeout checklist performed. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related to timeliness of grant closeout procedures. Context - In all samples tested, grant closeout procedures were completed; however, they were outside of an effective time window in order to meet the CFR requirements. The late reviews occurred between 134 days and 262 days after the period of performance ended. Two of the grant closeout checklists were not reviewed by an independent person once they were prepared. Cause and Effect - The University does have a formal grant closeout process in place, which includes a level of review of the grant checklist complete; however, the procedures were not followed or were misunderstood by certain staff, leading to procedures being completed late and a lack of review. Recommendation - The University should implement additional training over the procedures in place and consider whether any additional controls should be designed to mitigate the risk of procedures and reviews not being done in a timely manner. Views of Responsible Officials and Corrective Action Plan - SRS Accounting works closely with the departments on grant closeouts. Although a checklist was not signed by a supervisor, many of these awards had departmental agreement of final expenses. In two cases, the award was fully spent. System restrictions prevent spending 90 days after the grant end date. Due to department and system controls, no unallowable costs were reported on any award. SRS accounting will provide further award closeout training to its team members. Additionally, SRS Accounting added a supervisory team member, which will help mitigate this situation going forward.