Finding Text
Finding 2025-010 – Special Tests and Provisions: Key Personnel Changes – Significant Deficiency in Internal Control Over Compliance; Agencies – Department of Health and Human Services, National Science Foundation, National Aeronautics and Space Administration, Department of Agriculture; Assistance Listing Numbers (ALN) - 93.859, 47.083, 47.050, 93.310, 43.008, 10.699, 47.078; Program Name - Research and Development Cluster; Award Year / Award Number – FY 2025, 2024, 2023, 2022, 2021, 2020 / Awards ANTHC- 23-U-396186; 5U24GM146576-02; 2049596; 2243258; ICER 2040729, Subaward 15660316; FIAN 2220560; ICER 1928230; Subaward 1558528; ICER 2052107; 2127346; 2309480; 80NSSC20M0070; 80NSSXC20M0070; 80NSSC24M0179, 24-MIRO-0054;1333MF4P0220; 18-JV-11261944-100; 2325081; 2419971, subaward 24-S37; Criteria or Specific Requirement – 2 CFR 200.308 requires recipients to obtain prior written approval from the federal awarding agency or pass-through entity for certain post-award changes, including changes in key personnel specified in the federal award. Accordingly, management should have controls in place to identify key personnel requirements, monitor changes in assigned personnel, and obtain required approvals before making such changes.; Condition – APU does not have a process or policy in place for review or tracking of notifications and approvals of personnel changes by the applicable federal awarding agency or pass-through entity.; Cause – APU did not have a centralized policy or procedure to periodically track and monitor key personnel identified in federal awards and evaluate whether any changes required communication to the applicable federal awarding agency or pass-through entity.; Effect or Potential Effect – Failure to identify and communicate changes in key personnel may result in noncompliance with the terms and conditions of the federal award.; Questioned Costs - None reported.; Context – We selected five grants out of a total of 19 with personnel notification requirements. There were no exceptions to the notification requirements noted. However, there was no tracking mechanism or policy in place to ensure this notification and approval is done timely and in accordance with grant requirements.; Repeat Finding – This is not a repeat finding.; Recommendation – We recommend that management establish formal procedures to identify key personnel requirements in federal awards and maintain a centralized tracking process to monitor assigned key personnel throughout the award period. The procedures should include periodic review of key personnel assignments, evaluation of whether changes require communication to the federal awarding agency or pass-through entity, and retention of documentation supporting the review and any related communications.; Views of Responsible Officials – Management concurs with the finding and is implementing a centralized process to monitor key personnel requirements and required agency notifications.