Finding 372071 (2023-001)

Finding 2023-001 Allowable costs/cost principles – Cost Transfers Federal Agency: Department of Health and Human Services, National Institutes of Health Department of Health and Human Services, Health Resources and Services Administration (HRSA) Program: Research and Development Cluster Sickle Cell Treatment Demonstration Program Assistance Listing #: 93.395, 93.242 93.365 Award #: 5R01CA25831102, 5R01MH11676804 2U1EMC278650800 Award Year: 7/1/2022 – 6/30/2023, 7/1/2022 – 6/30/2023 9/1/2021 – 8/31/ 2022 Pass-through Number: Not applicable Not applicable Criteria The National Institute of Health’s (NIH) Grants policy manual requires cost transfers to NIH grants by recipients, consortium participants, or contractors under grants that represent corrections of clerical or bookkeeping errors to be accomplished within 90 days of when the error was discovered. The Department of Health and Human Services Grants policy manual requires permissible cost transfers to be made promptly after the error occurs but no later than 90 days following occurrence unless a longer period is approved in advance by the Grants Management Office. The University’s Cost Transfer policy requires cost transfers to be allocable, allowable, reasonable, and submitted in a timely manner. Condition Research and Development Cluster We selected 25 cost transfers, which included cost transfers related to payroll and non-payroll costs, totaling $368,956. During our testing, we noted 2 of 25 cost transfers, totaling $24,438, that were not completed within the timeframe noted above. The cost transfers were completed 8 to 16 days late. Other Major Program - Sickle Cell Treatment Demonstration Program We selected 19 cost transfers, which included cost transfers related to payroll and non-payroll costs, totaling $28,628. During our testing, we noted 1 of 19 cost transfers, totaling $4,951, that was not completed within the timeframe noted above. The cost transfer was completed 55 days late. Cause The university has a cost transfer policy which includes a requirement for cost transfers to be made in a timely manner. However, there were certain instances where there were delays in processing cost transfers which ultimately resulted in the completion of the cost transfer process outside of the timeframe required by the regulations. Effect There were certain cost transfers that were processed outside of the timeframe that is allowed by the federal regulations. Questioned Costs There are no questioned costs associated with this finding as the costs transferred were allowable and allocable to the awards to which they were transferred. Recommendation We recommend management continue to educate staff on the cost transfer policy, with a specific emphasis on the importance of processing cost transfers in a timely manner. Views of Responsible Officials Please refer to management’s views and corrective action plan.