Finding Text
Finding 2024-009: Reporting Program Title: Defense Nuclear Nonproliferation Research Assistance Listing Number: 81.113 Federal Agency: U.S. Department of Energy Direct Award Identifying Numbers: DE-NA003862, DE-NA004179, DE-NA0004177 Federal Award Year: Year ended September 30, 2024 Program Title: Export Control and Related Border Security Assistance Listing Number: 19.901 Federal Agency: U.S. Department of State Direct Award Identifying Number: SAQMIP23CA0153 Pass-Through Entity Name, Pass-Through Identifying Number: The Research Foundation for SUNY, University at Albany, 3-98939 Federal Award Year: Year ended September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Compliance Finding Criteria: Per 2 CFR §200.327 and §200.328, non-Federal entities must submit required financial and performance reports by the specified due dates and maintain effective internal controls to ensure accuracy and compliance. Review and approval of reports is a key internal control. Condition: During the audit, we noted a lack of documented supervisory review and approval of financial reports and performance reports prior to submission. We also noted certain reports in our sample were filed a day late or not at all. Cause: PFI has not implemented formal procedures for documenting supervisory review of reports and lacks a tracking mechanism for reporting deadlines. Effect or Potential Effect: Without documented controls over reporting, there is a reasonable possibility that PFI could submit inaccurate or incomplete reporting. Late submissions may hinder the Federal agency’s ability to monitor program performance and compliance and could result in administrative actions or delays in funding. Questioned Costs: None noted. Context: Under 81.113, 4 of 4 financial reports and 4 of 4 performance reports selected for testing did not have documented evidence of supervisory review and approval. Under 19.901, 4 of 4 financial reports and 4 of 4 performance reports selected for testing did not have documented evidence of supervisory review and approval. Under ALN 19.901, 2 out of 4 financial reports and 1 out of 4 performance reports selected for testing were filed 1 day late. For one subaward under ALN 19.901, quarterly performance reports were a noted requirement per the subaward agreement, however, no reports were filed during the year under audit. Recommendation: We recommend that PFI implement a formal review and approval process for all required reports, including maintaining evidence of supervisory sign-off, including date of review. Additionally, we recommend that PFI establish a reporting calendar with automated reminders and assign responsibility for monitoring deadlines to ensure timely submission.