Finding 1162745 (2023-004)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2023
Accepted
2025-11-20

AI Summary

  • Core Issue: CUAHSI improperly drew down $4,930,416 in federal funds before incurring eligible expenses, leading to $466,614 in excess advances.
  • Impacted Requirements: This violates the cash management guidelines outlined in CFR § 200.305 and the specific conditions in Chapter VIII.C.3 of the NSF grant agreement.
  • Recommended Follow-Up: CUAHSI should establish and enforce controls to ensure compliance with federal cash management policies to avoid potential penalties and funding disqualification.

Finding Text

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering & Office of International Science and Engineering AL No.: 47.050, 47.070 & 47.079 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2023), EAR- 2244446 (03/01/2023 – 02/28/2026), OAC-2209833 (01/01/2023 – 12/31/2026), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2024), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026) & OISE-1855654 (05/15/2019 – 12/31/2023) Pass Through Entity: None MW2023-004 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 2023, CUAHSI had advance drawdowns totaling $4,930,416 from the NSF. Of this amount, CUAHSI incurred $4,463,802 in eligible expenses for the year ended December 31, 2023. This resulted in $466,614 in excess federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2023 are reported as part of the advances payable liability 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 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 MW2022-007. 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.

Corrective Action Plan

Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHS! impacting audit year 2023: Certain 2023 draws were processed as advances outside grant guidelines, although these draws were properly recorded as advances payable in the accounting records. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI considers this finding resolved. A written drawdown procedure is now in place, requiring two-tier preparation and review, and, for working-capital advances, written approval from the prime funder. When the non-compliance was identified, CUAHSI suspended all NSF draws (late March 2023) until new controls were implemented. On 15 June 2023, CUAHSI completed its first draw under the revised policy. Name of Contact Person: • Jordan S Read, Chief Executive Officer • Telephone: (339)933-4660 • Email: jread@cuahsi.org Projected Completion Date: NA; is complete

Categories

Cash Management

Other Findings in this Audit

  • 1162734 2023-001
    Material Weakness Repeat
  • 1162735 2023-002
    Material Weakness Repeat
  • 1162736 2023-003
    Material Weakness Repeat
  • 1162737 2023-004
    Material Weakness Repeat
  • 1162738 2023-001
    Material Weakness Repeat
  • 1162739 2023-002
    Material Weakness Repeat
  • 1162740 2023-003
    Material Weakness Repeat
  • 1162741 2023-004
    Material Weakness Repeat
  • 1162742 2023-001
    Material Weakness Repeat
  • 1162743 2023-002
    Material Weakness Repeat
  • 1162744 2023-003
    Material Weakness Repeat
  • 1162746 2023-001
    Material Weakness Repeat
  • 1162747 2023-002
    Material Weakness Repeat
  • 1162748 2023-003
    Material Weakness Repeat
  • 1162749 2023-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
47.050 GEOSCIENCES $3.65M
11.432 NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION (NOAA) COOPERATIVE INSTITUTES $1.02M
47.070 COMPUTER AND INFORMATION SCIENCE AND ENGINEERING $376,326
47.079 OFFICE OF INTERNATIONAL SCIENCE AND ENGINEERING $25,407
43.001 SCIENCE $13,006