Finding Text
2025-008. FINDING - Noncompliance with Reimbursements to Subrecipients Federal Agency: National Science Foundation Assistance Listing Numbers: 47.070 Program Names and Award Numbers: Research and Development Cluster: CISE-MSI: RPEP: S&CC: Information Systems meet Cultural Competencies; CISE-MSI: DP: IIS-III: ACOSUS: An AI-driven counseling System for Underrepresented Transfer Students Award Numbers: 2131291 – 2021; 2219623 – 2022 Questioned Costs: None Northeastern Illinois University (University) did not pay reimbursements within 30 days for certain subrecipients in the Research and Development Cluster. CONDITIONS FOUND & CRITERIA: For three of 10 (30%) subrecipient invoices selected for testing in the Research and Development Cluster, the University made payments in a time period greater than 30 days. The sample was not intended to be, and was not, a statistically valid sample. Uniform Guidance (2 CFR 200.305(b)(3)) requires, for recipients and subrecipients other than states, payment methods must minimize the time elapsing between the transfer of funds from the federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient, regardless of whether the payment is made by electronic funds transfer or by other means. Further, when the reimbursement method is used for payment, organizations must make a payment within 30 calendar days after receipt of the billing unless the federal awarding agency or pass-through entity reasonably believes the request to be improper. CAUSE: University officials stated the department did not timely enter invoices into the Accounts Payable system which resulted in delayed processing by Accounts Payable, thus the payment was not made in accordance with the Uniform Guidance. EFFECT: Failure to meet subrecipients payment requirements is noncompliance with federal regulations and could result in loss of grant funding in future years. (Finding Code No. 2025-008) RECOMMENDATION: We recommend the University implements processes and controls to ensure that payments to subrecipients are made in accordance with the Uniform Guidance. UNIVERSITY RESPONSE: The University agrees with the recommendation. This issue was due to one department’s oversight in maintaining and providing appropriate documentation. The department was sent a reminder of the expectation of timely filing all required documentation to ensure payments to subrecipients are made in accordance with the Uniform Guidance.