Finding 1223840 (2025-003)

Material Weakness Repeat Finding
Requirement
F
Questioned Costs
-
Year
2025
Accepted
2026-07-16
Audit: 407295
Organization: Union College (NY)
Auditor: KPMG LLP

AI Summary

  • Core Issue: The College failed to conduct required bi-annual inventory counts and lacked documentation for equipment disposals, leading to potential non-compliance with federal regulations.
  • Impacted Requirements: Non-adherence to 2 CFR 200.313 for equipment tracking and disposal, and insufficient internal controls as outlined in 2 CFR 200.303(a).
  • Recommended Follow-Up: Conduct a comprehensive physical inventory audit, update equipment records, and establish formal disposal policies to ensure compliance with federal guidelines.

Finding Text

Finding No.: 2025-003- Equipment – Material weakness and material non-compliance Federal Agency: Various Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2024 – June 30, 2025 Criteria Institutions with federally acquired research and development equipment must adhere to specific guidelines outlined in 2 CFR 200.313. This regulation mandates that entities conduct bi-annual inventory counts of federally acquired equipment to ensure accurate tracking and accountability. It requires maintaining detailed records of all equipment, including acquisition date, cost, location, and current status, to reflect any changes or discrepancies following each inventory count. Additionally, the regulation specifies procedures for the appropriate disposal of federally acquired equipment that is no longer needed or has reached the end of its useful life. Entities must request disposal instructions from the federal awarding agency and ensure that disposal methods comply with federal regulations, including obtaining necessary approvals and documenting the disposal process. Furthermore, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Conditions Found During our testing over equipment, we identified that the College did not conduct an inventory count in the fiscal year under audit or the preceding fiscal year. During our testing over equipment dispositions, we noted that the College maintains a listing of equipment disposals, this listing did not include the date of disposition. Additionally, management was unable to provide documentation demonstrating that during the disposition of equipment the College requested disposition instructions from the federal awarding agency, when required by the terms and conditions of the award and was unable to provide supporting documentation of the individual disposals. Cause The cause of this condition was that the College did not follow its internal policies to conduct a physical inventory count, which contributed to the inability to track the specific timing of equipment retirements. Furthermore, the College lacked formally written policies and procedures governing the disposal of federally acquired equipment to ensure the disposal process, including obtaining necessary approvals, is documented and executed in compliance with Uniform Guidance. Possible Asserted Effect Improper disposal practices and the failure to perform a physical inventory count compromise the integrity of inventory management. Moreover, the absence of formal policies could result in federal noncompliance. Questioned Costs No questioned costs were identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding The conditions found constitute a repeat finding from the prior year. Recommendation We recommend that management perform a thorough physical inventory audit to locate all equipment and update the master equipment listing with accurate details, including current locations and statuses. Additionally, we recommend the institution review and regularly circulate formal policies and procedures for the appropriate disposal of non-functional or obsolete equipment. This should include obtaining necessary approvals and documenting the disposal process as per federal guidelines and federal awarding agency instructions. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.

Corrective Action Plan

Federal Agency: Various Federal Program: Research and Development Cluster Assistance Listing Number: Various Federal Award Numbers: Various Finding No.: 2025-003 Corrective Action Plan: The College will continue to strengthen and monitor internal controls over the management of federally funded equipment to sufficiently address this finding. The College completed a comprehensive physical inventory of federally-funded equipment as of June 30, 2026. The inventory results were successfully reconciled to the College's fixed asset register. Going forward the accounting group, in collaboration with the Office of Sponsored Programs and departmental equipment custodians, will perform and document the required physical inventory, update the asset register to reflect current locations and statuses, and maintain complete documentation supporting all inventory activities. Developed in accordance with federal requirements, the College also implemented a new equipment disposal policy for all federally-funded equipment, effective July 1, 2026. Timeline for Implementation of Corrective Action Plan: The College completed the corrective action plan by June 30, 2026. Management will periodically monitor compliance to ensure federally-funded equipment is properly inventoried, documented, and disposed of in accordance with federal requirements.

Categories

Equipment & Real Property Management

Other Findings in this Audit

  • 1223797 2025-002
    Material Weakness Repeat
  • 1223798 2025-002
    Material Weakness Repeat
  • 1223799 2025-002
    Material Weakness Repeat
  • 1223800 2025-002
    Material Weakness Repeat
  • 1223801 2025-002
    Material Weakness Repeat
  • 1223802 2025-002
    Material Weakness Repeat
  • 1223803 2025-002
    Material Weakness Repeat
  • 1223804 2025-002
    Material Weakness Repeat
  • 1223805 2025-002
    Material Weakness Repeat
  • 1223806 2025-002
    Material Weakness Repeat
  • 1223807 2025-002
    Material Weakness Repeat
  • 1223808 2025-002
    Material Weakness Repeat
  • 1223809 2025-002
    Material Weakness Repeat
  • 1223810 2025-002
    Material Weakness Repeat
  • 1223811 2025-002
    Material Weakness Repeat
  • 1223812 2025-002
    Material Weakness Repeat
  • 1223813 2025-002
    Material Weakness Repeat
  • 1223814 2025-002
    Material Weakness Repeat
  • 1223815 2025-002
    Material Weakness Repeat
  • 1223816 2025-002
    Material Weakness Repeat
  • 1223817 2025-002
    Material Weakness Repeat
  • 1223818 2025-002
    Material Weakness Repeat
  • 1223819 2025-003
    Material Weakness Repeat
  • 1223820 2025-003
    Material Weakness Repeat
  • 1223821 2025-003
    Material Weakness Repeat
  • 1223822 2025-003
    Material Weakness Repeat
  • 1223823 2025-003
    Material Weakness Repeat
  • 1223824 2025-003
    Material Weakness Repeat
  • 1223825 2025-003
    Material Weakness Repeat
  • 1223826 2025-003
    Material Weakness Repeat
  • 1223827 2025-003
    Material Weakness Repeat
  • 1223828 2025-003
    Material Weakness Repeat
  • 1223829 2025-003
    Material Weakness Repeat
  • 1223830 2025-003
    Material Weakness Repeat
  • 1223831 2025-003
    Material Weakness Repeat
  • 1223832 2025-003
    Material Weakness Repeat
  • 1223833 2025-003
    Material Weakness Repeat
  • 1223834 2025-003
    Material Weakness Repeat
  • 1223835 2025-003
    Material Weakness Repeat
  • 1223836 2025-003
    Material Weakness Repeat
  • 1223837 2025-003
    Material Weakness Repeat
  • 1223838 2025-003
    Material Weakness Repeat
  • 1223839 2025-003
    Material Weakness Repeat
  • 1223841 2025-004
    Material Weakness Repeat
  • 1223842 2025-004
    Material Weakness Repeat
  • 1223843 2025-004
    Material Weakness Repeat
  • 1223844 2025-004
    Material Weakness Repeat
  • 1223845 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $8.51M
84.063 FEDERAL PELL GRANT PROGRAM $2.44M
84.033 FEDERAL WORK-STUDY PROGRAM $313,604
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $245,409
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $101,820
93.853 EXTRAMURAL RESEARCH PROGRAMS IN THE NEUROSCIENCES AND NEUROLOGICAL DISORDERS $86,501
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $83,267
47.041 ENGINEERING $77,068
47.084 TECHNOLOGY, INNOVATION, AND PARTNERSHIPS $58,397
16.525 GRANTS TO REDUCE DOMESTIC VIOLENCE, DATING VIOLENCE, SEXUAL ASSAULT, AND STALKING ON CAMPUS $55,706
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $40,015
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) $22,953
43.001 SCIENCE $19,976
47.050 GEOSCIENCES $16,047
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $12,264
93.143 NIEHS SUPERFUND HAZARDOUS SUBSTANCES_BASIC RESEARCH AND EDUCATION $8,081
93.286 DISCOVERY AND APPLIED RESEARCH FOR TECHNOLOGICAL INNOVATIONS TO IMPROVE HUMAN HEALTH $3,427