FAC Explorer

Finding 1127684 (2024-001)

-
Requirement
F
Questioned Costs
$1
Year
2024
Accepted
2025-03-31
Audit: 352087
Organization: Temple University (PA)
Auditor: Deloitte & Touche LLP

AI Summary

  • Core Issue: The University failed to obtain required disposition instructions from the funding agency when transferring equipment valued over $5,000 to another university.
  • Impacted Requirements: This non-compliance violates federal regulations outlined in 2 CFR section 200.313 regarding Equipment and Real Property Management.
  • Recommended Follow-Up: Ensure that all equipment transfers include a request for disposition instructions from the federal awarding agency and update internal policies to reflect this requirement.

Finding Text

Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.

Categories

Questioned Costs Equipment & Real Property Management HUD Housing Programs Matching / Level of Effort / Earmarking

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $58.28M
84.063 Federal Pell Grant Program $40.39M
84.063 Federal Supplemental Educational Opportunity Grants $2.62M
84.033 Federal Work Study Program $2.59M
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $1.90M
93.185 Immunization Reseatch, Demonstation, Public Information and Education Training and Clinical Skills Improvement Project $1.45M
84.048 Career and Technical Education -- Basic Grants to States $1.01M
93.310 Trans Nih Research Support $924,315
12.431 Basic Scientific Research $845,003
93.464 Acl Assistive Technology $792,679
93.747 Elder Abuse Prevention Interventions Program $696,076
93.243 Substance Abuse and Mental Health Services $688,842
84.325D Special Education - Personal Development to Improve Services and Results for Children with Disabilities $672,937
21.027 Coronavirus State and Local Fiscal Recovery Funds $656,138
84.365 Sickle Cell Treatment Demonstration Program $635,098
93.297 Teenager Pregancy Prevention Program $616,839
98.001 Usaid Foreign Assistance for Programs Overseas $605,166
93.351 National Center for Advancing Translational Sciences $599,770
93.RD8 National Institues of Health Contract $563,560
21.027 Covid-19 - Coronavirus State and Local Fiscal Recovery Funds $510,226
16.839 Stop School Violence $506,504
93.994 Maternal and Child Health Services Block Grant to the States (a) $502,424
93.879 Medical Library Assistance $463,911
93.RD9 Center for Disease Control Contract $439,342
47.083 Office of Integrative Activities $378,658
12.401 National Guard Military Operations and Maintenance (o&m) Projects $364,172
93.084 Translation and Implementation Science Research for Heart, Lung, Blood Diseases, and Sleep Disorders (b) $338,149
93.273 Alcohol Research Programs $286,481
93.398 Cancer Research Manpower $278,710
84.038 Federal Perkins Loan Program $278,594
47.076 Stem Education $256,486
84.425U Covid-19-Education Stabilization Fund Under the Coronavirus Aid, Relief, and Economic Security Act $250,014
16.575 Crime Victim Assistance $241,090
84.220A Centers for International Business Education Program $237,301
11.307 Economic Adjustment Assistance $224,521
84.047 Trio_upward Bound $222,413
84.324 Program Announcement: Special Topics $219,259
84.305 Education Research, Development and Dissemination $211,213
12.225 Commercial Technologies for Maintenance Activities Program (b) $208,331
93.136 Injury Prevention and Control Research and State and Community Based Programs $202,557
93.RD1 National Institutes of Health Contract $188,618
47.RD1 Natioal Science Foundation Contract $187,513
93.070 Environmental Public Health and Emergency Response $186,429
21.008 Low Income Taxpayer Clinics $186,315
84.336 Teacher Quality Partnership Grants $179,563
93.493 Congressional Directives (b) $176,470
32.U03 Federal Communications Commission $174,802
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation's Health $173,190
16.585 Treatment Court Discretionary Grant Program $162,886
84.287 Title Iv, Part B of Esea $156,599
93.342 Heath Professions Student Loans $155,650
47.049 Mathematical and Physical Sciences $149,850
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $141,076
93.778 Medical Assistance Program $137,091
21.027 Covid-19-Coronavirus State and Local Fiscal Recovery Funds $130,744
97.061 Centers for Homeland Security $121,062
93.092 Affordable Care Act (aca) Personal Responsibility Education Program (a, B) $117,022
93.924 Ryan White Hiv/aids Dental Reimbursement and Community Based Dental Partnership Grants (a, B) $108,994
12.RD8 US Department of Defense Contract $108,900
16.045 Community-Based Violence Intervention and Prevention Initiative $108,180
93.914 Hiv Emergency Relief Project Grants $104,756
93.639 Section 9813: State Planning Grants for Qualifying Community-Based Mobile Crisis Intervention Services $102,301
81.135 Advanced Research Projects Agency - Energy $101,106
81.086 Conservation Reserch and Development $97,756
93.279 Drug Abuse and Addiction Research Programs $97,025
16.738 Edward Bryne Memorial Justice Assistance Grant Program $94,959
93.217 Family Planning Services $91,940
12.RD1 US Department of Defense Contract $87,261
81.RD8 US Department of Energy Contract $85,590
10.310 Agriculture and Food Research Initiative (afri) $85,552
12.740 Past Conflict Accounting $85,546
93.U13 National Institues of Health Contract $83,372
64.RD2 US Veterans Administration Contract $77,874
93.RD4 National Institutes of Health Contract $77,795
47.079 Office of International Science and Engineering $74,983
19.040 Public Diplomacy Programs $74,173
43.001 Science $72,944
93.262 Occupational Saftey and Health Program $71,891
47.070 Computer and Information Science and Engineering $69,688
10.309 Museum Grants for African American History and Culture $69,090
84.305A Education Research, Development and Dissemination $68,142
93.558 Temporary Assistance for Needy Families $68,035
93.172 Human Genome Research $66,902
93.RD6 National Institutes of Health Contract $66,885
47.070 Natioal Science Foundation Contract $66,810
81.049 Office of Science Financial Assistance Program $66,296
64.RD3 US Veterans Administration Contract $65,012
84.407 Transition Programs for Students with Intellectual Disabilities Into Higher Education $64,576
93.121 Oral Diseases and Disorders Research $63,818
93.837 Cardiovascular Diseases Research $63,067
93.011 National Organizations of State and Local Officials $62,155
16.U09 US Department of Justice Contract $61,103
81.087 Renewable Energy Research and Development (b) $58,134
64.RD1 US Veterans Administration Contract $57,603
47.070 Computer and Information Science and Engineering $56,761
12.U02 US Department of Defense Contract $56,097
93.393 Cancer Cause and Prevention Research $50,702
10.025 Plant and Animal Disease, Pest Control, and Animal Care $50,325
43.008 Education $47,618
84.367 Supporting Effective Instruction State Grants $47,281
12.RD3 US Department of Defense Contract $43,871
47.041 Engineering Grants $41,211
16.026 Ovw Research and Evaluation Program $41,014
81.RD9 US Department of Energy Contract $40,062
12.U01 US Department of Defense Contract $39,756
93.855 Allergy and Infectious Diseases Research $39,304
93.110 Maternal and Child Health Federal Consolidated Programs $39,183
93.235 Affordable Care Act (aca) Abstinence Education Program $37,542
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $36,633
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $36,047
94.006 Americorps State and National $35,039
93.310 Trans-Nih Research Support $35,000
93.397 Cancer Centers Support Grants $34,704
10.310 Agriculture and Food Research Initiative (afri) (b) $33,492
93.839 Blood Diseases and Resources Research $32,418
84.126 Rehabilitation Services_vocational Rehabilitation Grants to States $32,375
93.424 Non-Aca/pphf—building Capacity of the Public Health System to Improve Population Health Through National Nonprofit Organizations $32,045
93.173 Research Related to Deafness and Communication Disorders $27,896
12.800 Air Force Defense Research Sciences Program $27,597
93.394 Cancer Detection and Diagnosis Research $26,787
14.889 Tribal Hud-Va Supportive Housing Program $26,228
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $25,919
15.657 Endangered Species Recovery Implementation $25,198
15.945 Cooperative Research and Training Programs – Resources of the National Park System $24,728
12.RD9 US Department of Defense Contract $24,443
47.041 Engineering $24,149
12.420 Military Medical Research and Development $23,702
93.860 Emerging Infections Sentinel Networks $23,145
20.205 Highway Planning and Construction $22,801
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $21,974
93.213 Research and Training in Complementary and Integrative Health $21,811
93.RD5 National Institutes of Health Contract $21,487
93.226 Research on Healthcare Costs, Quality and Outcomes $20,575
84.022 Overseas Programs - Doctoral Dissertation Research Abroad $20,175
93.866 Aging Research $19,253
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $17,550
93.113 Environmental Health $17,511
93.867 Vision Research $17,391
93.323 Epidemology and Laboratory Capacity for Infectious Diseases (elc) $17,293
93.940 Hiv Prevention Activities Health Department Based $17,196
47.075 Social, Behavioral, and Economic Sciences $16,306
11.463 Habitat Conservation (b) $16,038
93.242 Mental Health Research Grants $15,032
45.024 Promotion of the Arts Grants to Organizations and Individuals $15,000
10.250 Agricultural and Rural Economic Research, Cooperative Agreements and Collaborations (b, L) $14,851
15.805 Assistance to State Water Resources Research Institutes $14,372
93.RD9 National Institues of Health Contract $13,150
12.351 Scientific Research - Combating Weapons of Mass Destruction $12,534
93.U12 National Institutes of Health Contract $12,227
12.RD2 US Department of Defense Contract $12,057
47.078 Polar Programs $11,526
45.312 National Leadership Grants $11,445
21.009 Volunteer Income Tax Assistance (vita) Matching Grant Program $11,392
10.253 Consumer Data and Nutritional Research $11,121
93.307 Minority Health and Health Disparities Research $10,376
93.103 Food and Drug Administration_research $10,269
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $10,206
93.145 Hiv-Related Training and Techincal Assistance $10,028
47.074 Biological Sciences $10,005
93.865 Child Health and Human Development Extramural Research $9,364
12.431 Military Medical Research and Development $8,500
15.954 National Park Service Conservation Protection, Outreach and Education $8,261
17.259 Wioa Youth Activities $8,192
32.U10 Federal Communications Commission Contract $7,976
10.707 Research Joint Venture and Cost Reimbursable Agreements (c) $7,833
93.395 Cancer Treatment Research $7,305
93.059 Training in General, Pediatric and Public Health Dentistry $7,206
15.506 Water Desalination Research and Development $6,971
47.050 Geosciences $6,799
93.859 Biomedical Research and Research Training $6,758
11.011 Ocean Exploration $6,562
16.523 Juvenile Accountability Block Grants $5,693
12.630 Basic Applied and Advance Research in Science and Engineering $5,258
93.200 Administrative Action $5,093
93.659 Adoption Assistance (a) $4,793
81.RD6 US Department of Energy Contract $4,438
93.630 Developmental Disabilities Basic Support and Advocacy Grants (a) $4,207
93.674 Chafee Foster Care Independence Program $4,013
81.RD1 US Department of Energy Contract $3,690
93.364 Nursing Student Loan $3,556
10.699 Partnership Agreements $3,306
84.002A Adult Education: Basic Grants to States $3,017
93.788 Opioid Str $2,967
15.926 American Battlefield Protection $2,960
95.006 Model Acts Program $2,521
93.840 Translation and Implementation Research for Heart, Lung, Blood Diseases and Sleep Disorders $2,470
93.958 Block Grants for Community Mental Health Services (a,b) $2,306
15.670 Adaptive Science $2,289
93.838 Lung Diseases Research $2,158
93.396 Cancer Biology Research $2,097
59.037 Small Business Development Centers $1,959
47.084 Office of Integrative Activities $1,711
17.261 Workforce Data Quality Initiative (wdqi) $1,680
84.220 Centers for International Business Education Program $1,607
64.RD4 US Veterans Administration Contract $1,505
93.RD7 National Institutes of Health Contract $1,182
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $1,121
17.270 Reentry Employment Opportunities $1,091
16.582 Crime Victim Assistance/discretionary Grants $999
45.U06 National Endowment for the Humanities Contract $925
12.RD7 US Department of Defense Contract $508
10.215 Sustainable Agriculture Research and Education $344
43.U11 National Air & Space Administration Contract $242
16.123 Community_based Violence Prevention Program $217
93.667 Social Services Block Grant $205
32.U05 Federal Communications Commission $193
93.RD2 National Institutes of Health Contract $150
64.U07 US Department of Veteran's Affairs Contract $121
15.931 Youth and Veteran Organizations Conservation Activities $41
81.RD5 US Department of Energy Contract $24
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $24
93.069 Public Health Emergency Preparedness (b) $21
81.RD2 US Department of Energy Contract $3
12.RD5 US Department of Defense Contract $1
93.006 State and Territorial and Technical Assistance Capacity Development Minority Hiv/aids Demonstration Program $-14
84.425C Covid-19-Education Stabilization Fund Under the Coronavirus Aid, Relief, and Economic Security Act $-32
81.RD4 US Department of Energy Contract $-69
93.632 University Centers for Excellence in Developmental Disabilities Education, Research, and Service $-88
11.417 Sea Grant Support (b) $-194
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $-307
59.RD1 US Small Business Administration Contrct $-411
47.075 Computer and Information Science and Engineering $-435
14.506 General Research and Technology Activity $-436
84.002 Adult Education - Basic Grants to States $-551
10.RD1 US Department of Agriculture Contract $-689
84.424 Student Support and Academic Enrichment Program (a) $-975
32.U04 Federal Communications Commission $-1,366
32.001 Science $-1,496
16.601 Corrections_training and Staff Development $-1,885
84.411 Education Innovation and Research (formerly Investing in Innovation (i3) Fund) (b) $-1,996
12.420 Military Medical Research and Development $-2,021
93.361 Nursing Research $-2,730
12.300 Basic and Applied Scientific Research $-6,149
93.079 Cooperative Agreements to Promote Adolescence Health Through School-Based Hiv/std Prevention and School-Based Survelliance $-11,103
93.137 Community Programs to Improve Minority Health Grant Program $-12,583
93.048 Special Programs for the Aging,title Iv, Title Ii, Discretionary Projects $-13,651
93.072 Lifespan Respite Care Program $-20,323
84.196 Education for Homeless Children and Youth (a) $-22,093
11.432 National Oceanic and Atmospheric Administration $-28,039
64.RD1 US Department of Veteran's Affairs Contract $-28,826
93.RD3 National Institutes of Health Contract $-32,912
81.RD7 US Department of Energy Contract $-44,886
93.350 National Center for Advancing Translational Sciences $-172,295
12.RD4 US Department of Defense Contract $-377,775