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
MW2021-009 PROGRAM INCOME
Material Weakness
Criteria
Pursuant to 2 CFR 200 for award objectives and the regulations at 2 CFR 200.307, program
income is defined as “Gross income earned by the recipient that is directly generated by a
supported activity or earned as a result of the federal award during the period of performance” by
2 CFR Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements
for Federal Awards. Program income reporting is due forty five (45) days after the end of the
federal fiscal year. NSF requires that all cumulative program income is reported for all open
grants and agreements in the current year.
Condition
Program income consists of registration fees collected for training, meetings or workshops and
the proceeds from the sale of publications as a result of the federal award during the period of
performance. Program income is treated as an additive to the federal funds received by CUAHSI.
During a drawdown, program income reduces the amount that is requested to cover reimbursable
costs through the Flexible Billing module. This allows program income to be applied to the
award before a reimbursement is requested from NSF adding the value of program income
received to the awarded amount. Program income reporting is due forty five (45) days after the
end of the federal fiscal year. NSF requires that all cumulative program income is reported for all
open grants and agreements in the current year. CUAHSI program income totaled $31,525 for
the year ended December 31, 2021. CUAHSI failed to submit the required Program Income Reporting Worksheet by the required deadline of forty five (45) days after the end of the federal fiscal year (November 15, 2021) to ensure with the program income policies in accordance with the UG for the year ended December 31, 2021.
Cause & Context
Lack of resources and detailed attention to the risks, along with circumvention of controls has
resulted in weak internal controls, and conflicting or incomplete policies and procedures.
Effect
Non-compliance can lead to penalties, fines, or even termination of the contract. It may also
damage CUAHSI’s reputation and future eligibility for federal funding and jeopardize
CUAHSI’s ability to secure future grants or contracts from other funding agencies. Granting
organizations typically prioritize funding recipients with a track record of compliance and
accountability.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-009.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies
consistent with 2 CFR 200.307.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.