Finding Text
Finding No. 2024‑002 Research and Development Cluster:
Department of Health and Human Servies – National Institutes of Health:
Antibiotic-Free Anti-Infection Polymer Brush Biocoatings (ALN 93.286) Department of Education:
Pass-through from University of Massachusetts Boston:
Research and Innovation to Improve Services and Results for Children with Disability (ALN 84.324A) Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Presentation of Schedule of Expenditures of Federal Awards – Significant Deficiency. Criteria: As defined in 2 CFR section 200.1, Research and Development, “research” is a systematic study directed toward fuller scientific knowledge or understanding of the subject studied. “Development” is the systematic use of knowledge and understanding gained from research directed toward the production of useful materials, devices, systems, or methods, including design and development of prototypes and processes. R&D means all research activities, both basic and applied, and all development activities performed by non-federal entities. The term “research” also includes activities involving the training of individuals in research techniques where such activities utilize the same facilities as other R&D activities and when such activities are not included in the instruction function. The non-federal entity is required to cluster these grants into one federal program. As defined by Uniform Guidance (2 CFR 200), entities are required to present subrecipient expenses on the Schedule of Expenditures of Federal Awards (SEFA). Further, the non Federal entity must establish and maintain effective internal controls over the preparation of the SEFA that provides reasonable assurance that the non Federal entity is properly presenting Federal awards on the SEFA in accordance with the Uniform Guidance. Condition and Context: During the test work over the SEFA, we selected a sample of grant agreements to determine that the grants were properly presented on the SEFA. We identified two grants in the amount $45,021 that were not included in the Research of Development Cluster (RD). Once included, the total RD expenditures exceeded $750,000 and required RD to be audited as a major program. Additionally, through our test work over RD, there were subrecipient expenditures in the amount of $24,379 that were not disclosed on the SEFA. Cause: For one grant, management did not identify within the grant agreement that it was indicated to be an RD grant. For another grant it was included in the RD cluster, but not properly included in the RD total on the SEFA. The subrecipient expenditures related to a grant where the Principal Investigator (PI) left the University in the middle of fiscal year 2024. The PI did not properly code the expenses to a subrecipient expenditure general ledger code prior to leaving. Effect: If grants are not properly identified as part of RD, then the program may not be properly classified as Type A or Type B program, which may cause an inappropriate risk assessment to be performed. In addition, if expenditures are not classified in the appropriate expenditure category, then the population of expenditures subject to audit may not be complete and accurate, resulting in certain suggested audit procedures not being performed. Questioned Costs: There were no questioned costs related to this finding. Recommendation: We recommend that the University strengthen its policies and procedures over the presentation of the SEFA. Management should review the SEFA, along with all the grant agreements to ensure that all elements of the SEFA are accurately included and all expenditures and cluster are complete. Views of Responsible Official: Management agrees with the recommendation. The University will implement an additional level of review within the Finance Department over the Schedule of Expenditures of Federal Awards in order to ensure accuracy and completeness of the schedule. In addition, there will be inclusion of the Office of Grants and Sponsored Projects in the preparation and review of the schedule. The University is also looking into the implementation of software for award management to help avoid future oversights.