Finding 1175494 (2024-002)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2024
Accepted
2026-02-26
Audit: 389284
Organization: Robert Morris University (PA)

AI Summary

  • Core Issue: There was a significant deficiency in cash management controls, leading to premature drawdowns of federal funds before expenses were incurred.
  • Impacted Requirements: This practice violates Uniform Guidance, resulting in noncompliance for 2 out of 6 drawdowns related to the R&D cluster.
  • Recommended Follow-Up: Strengthen internal controls to ensure expenditures are incurred before drawdown requests, and consider enhanced management reviews for compliance.

Finding Text

Finding: 2024‐002 Cash Management - Significant Deficiency in Internal Control and Noncompliance Criteria: Uniform Guidance requires the auditee on the reimbursement method to incur expenditures prior to the date of the reimbursement request. Condition: For the year ended May 31, 2024, there were 2 of 6 selected drawdowns made in relation to federal award expenditures for the Research & Development (R&D) cluster, including ALNs 47.076, 12.420, and 12.300, in which management erroneously drew down prior to the expenses being incurred. Cause: The University’s control environment over cash management and review did not include sufficient procedures to identify expenditures within the R&D cluster that had not yet been incurred, as required by Uniform Guidance and the Office of Management and Budget (OMB) Compliance Supplement. Effect and Perspective: The premature draw down of federal awards in 2 of the 6 selected from the 17 total draw downs resulted in noncompliance, at the time of the draw downs. All underlying expenditures were appropriately included in the SEFA and the financial statements; however, the draw down for expenses prior to being incurred is considered a questioned cost and an instance of noncompliance. By the end of the fiscal year, May 31, 2024, the timing differences related to when expenses were incurred and when funds were drawn down was fully resolved. Questioned costs: $83,375. The expenses drawn down prematurely, were offset in subsequent quarters. However, as funds were only drawn down on a quarterly basis, the initial advance drawdown was inconsistent with compliance requirements. Lastly, by the audit period ending May 31, 2024, total life-to-date expenses were $513,529, while total cash drawn down was $470,530, indicating the grant was underdrawn as of May 31, 2024 by $42,999. Recommendation: We recommend that management strengthen internal controls over the review of draw down requests, specifically ensuring expenditures are incurred prior to the draw down request in accordance with Uniform Guidance and the OMB Compliance Supplement. Management should consider implementing enhanced management review controls to ensure expenditures are incurred prior to the associated draw down requests. View of Responsible Official and Planned Corrective Action: See Corrective Action Plan.

Corrective Action Plan

Audit Response to Finding 2024-002 to Uniform Guidance Audit - Advanced Drawdown Acknowledgement and Concurrence: Management acknowledges that two out of the six drawdowns selected for testing within the Research & Development (R&D) cluster were requested prior to the actual incurrence of the underlying expenditures. The University identified that the noncompliance was timing related only. A full year of stipend expenses were advance recorded in the general ledger and triggered the drawdown process prematurely. The University determined that this was an isolated incident unique to only one of the federal awards, and this issue has subsequently been corrected. While the grant was ultimately in a cumulative underdrawn position by year-end, we recognize that the reimbursement method under Uniform Guidance requires expenditures to be paid or incurred prior to the request for federal funds. Corrective Action Plan: • Enhanced Management Review: The University Controller’s Office will perform a "secondary review" of the GL date of the underlying expenditure versus the drawdown request date to ensure no "future-dated" or "anticipated" costs are included. • AP Policy Change: The University has revised its stipend processing workflow to ensure that payments are scheduled according to the service period rather than the entry date, and no longer will 12 months of stipend payments be entered in AP at one time. Responsible Party: Joseph J. Piccirilli, Chief Accounting Officer and Controller Completion Date: March 2026

Categories

Cash Management Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1175486 2024-002
    Material Weakness Repeat
  • 1175487 2024-002
    Material Weakness Repeat
  • 1175488 2024-002
    Material Weakness Repeat
  • 1175489 2024-002
    Material Weakness Repeat
  • 1175490 2024-002
    Material Weakness Repeat
  • 1175491 2024-002
    Material Weakness Repeat
  • 1175492 2024-002
    Material Weakness Repeat
  • 1175493 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $22.21M
84.063 FEDERAL PELL GRANT PROGRAM $4.52M
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $1.18M
47.076 STEM EDUCATION $479,570
84.033 FEDERAL WORK-STUDY PROGRAM $347,163
84.038 FEDERAL PERKINS LOAN PROGRAM $250,528
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $237,069
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $163,846
12.902 INFORMATION SECURITY GRANTS $77,726
12.420 MILITARY MEDICAL RESEARCH AND DEVELOPMENT $35,396
12.600 COMMUNITY INVESTMENT $23,023
12.300 BASIC AND APPLIED SCIENTIFIC RESEARCH $20,022
93.600 HEAD START $15,040
81.U00 LABORATORY EQUIPMENT DONATION PROGRAM $15,000
84.367 IMPROVING TEACHER QUALITY STATE GRANTS $9,800
45.312 NATIONAL LEADERSHIP GRANTS $1,189