Finding Text
Criteria Applications/proposals or awards may include staffing proposals that specify individuals who will work on the project and the extent of the planned involvement of personnel. 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 federal awards 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. Condition The Organization does not have formal policies and procedures to determine whether key personnel involved in projects were approved by the underlying contract funding agency. The Organization represented that it did obtain verbal approval for changes in the key personnel. Cause The Organization does not have formal policies and procedures regarding approval of key personnel on projects funded via federal awards. Effect The Organization is not able to provide evidence that it is in compliance with the special tests and provisions over key personnel. Questioned Costs None Context We performed testing over partnership intermediary agreements in effect for the period under audit. The Organization was not able to provide evidence of the key personnel being approved by the funding agency as required by the agreements. Recommendation The Organization should create formal policies and procedures that require retention of evidence of the funders' approval of any changes in identified key personnel. The Organization should also add policies and procedures in place to maintain a listing of all key personnel identified in the various partnership intermediary agreements. Views of Responsible Officials See the accompanying Corrective Action Plan.