Finding Text
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF
EXPENDITURES
Material Weakness
Criteria
CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the
management of cash drawdowns and disbursements of federal funds. Federal funds should be
disbursed in a timely manner for allowable costs that have been incurred. Cash advances must
meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National
Science Foundation.
Condition
CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with
the National Science Foundation which details the requirements for advance fundings. During
2021, CUAHSI had advance drawdowns totaling $1,172,645 from the NSF. Of this amount,
CUAHSI incurred $1,049,681 in eligible expenses for the year ended December 31, 2021. This
resulted in $122,964 in excess federal advances as of year-end. The draw downs in excess of
revenue recognized during the year ended December 31, 2021 are reported as part of deferred
revenue in the accompanying Statement of Financial Position.
Cause & Context
CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter
VIII.C.3 of the grant agreement.
Effect
Drawing down funds in advance of incurring eligible expenses could lead to non-compliance
with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need
to repay the funds, potential financial penalties, or disqualification from future federal funding.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-008.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies
consistent with 2 CFR 200.35.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.