Finding 370424 (2023-002)

Program Information Research and Development Cluster: ALN 47.076 NSF Robert Noyce Teacher Scholarship Program, ALN 93.213 Research and Training in Complementary and Alternative Medicine Federal Award Year: July 1, 2022 – June 30, 2023 Criteria or Requirement Title 2, U.S. Code of Federal Regulations Part 200 (2 CFR 200.332), Requirements for pass-through entities requires that all pass-through entities must verify that every subrecipient is audited (as required by 2 CFR Part 200 Subpart F) when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Title 200 part 2 CFR 200.303 states that the Institution, as a federal grant recipient, must “establish and maintain effective internal controls over the Federal awards 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. Condition found, including facts that support the deficiency identified in the finding and information to provide proper perspective for judging the prevalence and consequences of the finding For 3 subrecipients selected for testing, evidence of controls to ensure that subrecipients had been audited in accordance with by 2 CFR Part 200 Subpart F, or were not subject to audit, was not available. Cause and Possible Asserted Effect The University did not have sufficient controls over collection and review of audit reports of subrecipients under 2 CFR Part 200 Subpart F. Identification of questioned costs and how they were computed None Sample statistically valid The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding from prior year The audit finding is not a repeat finding. Recommendation We recommend that the University strengthen its controls over monitoring of subrecipients, in order to ensure that audit reports of subrecipients under 2 CFR Part 200 Subpart F are obtained and timely reviewed. Views on responsible officials Pacific University acknowledges the importance of an effective control environment and closely monitors activities of subrecipients under federal awards. Pacific was able to demonstrate that the selected subrecipients had appropriate audits under Subpart F (or were not subject to such audits). However, the University will enhance controls related to tracking such compliance.