Finding Text
2021-006 – SPECIAL TESTS AND PROVISIONS – KEY PERSONNEL
Federal Program Information:
Federal Agency
Federal Program Name Assistance Listing Number Grant Award(s) Unique Identifier(s)
Department of Defense Basic Scientific Research 12.431 W15QKN-14-1-0001
W15QKN-20-1-1000
Criteria:
2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award.” These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The award document specifies key personnel as chief investigators. Federal requirements stipulate the non-federal entity may change the staffing mix and level of involvement within limits specified by agency policy or in the award but may be required to obtain federal awarding agency approval of changes in key personnel (as identified in the award, which may differ from the non-federal entity’s designation in the application/proposal) and changes in the principal investigator’s/project director’s time commitment/level of participation in the project. For grants and cooperative agreements, this may include not only a change in the principal investigator or project director but also the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator (2 CFR sections 200.308(c) (2) and (3)).
Condition:
There was a lack of adequate payroll documentation. Payroll records did not demonstrate the level of time commitment and/or potential disengagement from the project by the designated principal investigators.
Questioned Costs:
Unknown.
Context:
Total federal expenditures listed on the Schedule of Federal Awards was $6,267,848, of which $232,167 was related to principal investigators.
SECTION III – FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (Continued)
2021-006 – SPECIAL TESTS AND PROVISIONS – KEY PERSONNEL (Continued)
Federal Program Information:
Federal Agency
Federal Program Name Assistance Listing Number Grant Award(s) Unique Identifier(s)
Department of Defense Basic Scientific Research 12.431 W15QKN-14-1-0001
W15QKN-20-1-1000
Cause:
Internal controls and procedures related to the payroll documentation were not effectively designed or performed.
Effect:
There is a risk that the principal investigators of the National Center for the Advancement of STEM Education, Inc. may not be allocating the proper time commitment to the project in accordance with federal guidelines.
Recommendation:
Management should establish proper policies and procedures which ensure payroll records clearly indicate the time commitment/level of participation in the project to comply with applicable federal
guidelines.
Views of Responsible Officials:
Management concurs with the finding and has developed a plan to correct the finding.