Finding Text
2022-008 Allowable Cost Determination and Subaward Monitoring
Research and Development Cluster (ALN 47.041-Engineering, Award 1940055, Award Period 9/1/19 – 8/31/22)
Federal Agency: National Science Foundation
Criteria: 2 CFR 200.403 requires that costs must have been incurred and recognized in accordance with generally accepted accounting principles (GAAP).
Condition: We selected 45 non-payroll expenses for testing. Of those 45, 1 was a journal entry to accrue for a passthrough payment to a subaward recipient. Supporting documentation indicated that this journal entry was recorded based on a budgeted amount and not actual performance by the subaward recipient.
Cause: The Organization lacked written policies and procedures to execute appropriate subaward monitoring responsibilities.
Effect: The Organization was not in compliance with 2 CFR 200.403 which requires that costs must be incurred and recognized in accordance with generally accepted accounting principles (GAAP). Without a policy to monitor the sub awardee, there is a risk that Organization passes through funds without verifying that the sub awardee has performed under the grant.
Identification as a repeat finding, if applicable: The finding is not a repeat finding of the prior year.
Recommendation: We recommend the Organization establish policy and procedures to monitor the sub awardee. These policies and procedures should include a requirement that the sub awardee presents supporting documentation to the Organization to demonstrate actual cost and performance under the agreement prior to the Organization recording the expense to the grant.
Response: The Organization will establish appropriate procedures for sub awardee monitoring.
Questioned Costs: None. An adjustment was posted to remove the costs that were booked based on budget from current year expenditures.