Finding 372183 (2023-001)

Significant Deficiency
Requirement
C
Questioned Costs
-
Year
2023
Accepted
2024-03-05
Audit: 293505
Organization: University of Cincinnati (OH)

AI Summary

  • Core Issue: Payments to subrecipients were made late, with 12 out of 28 payments exceeding the 30-day requirement.
  • Impacted Requirements: Compliance with 2 CFR 200.305(b)(3) regarding timely payments for federal awards.
  • Recommended Follow-up: Implement controls to ensure payments are made within 30 days and enhance training for staff on invoice processing.

Finding Text

Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 20.232, U.S. Department of Transportation, Commercial Driver's License Program Implementation Grant - 93.350, U.S. Department of Health and Human Services, National Center for Advancing Translational Sciences - 93.279, U.S. Department of Health and Human Services, Drug Abuse and Addiction Research Programs - 93.853, U.S. Department of Health and Human Services, Extramural Research Programs in the Neurosciences and Neurological Disorders - 93.866, U.S. Department of Health and Human Services, Aging Research Non-Research and Development Cluster: - 17.268, Department of Labor, H-1B Job Training Federal Award Identification Number and Year - Research and Development Cluster: - 20.323 - FM-CDL-0435-20-01-00 - 93.350 - UTR001425B - 93.279 - OSU SPC-1000006389 UM1DA; UDA013732E - 93.853 - SUBK00007313 SLEEP SMART; UNS110772A - 93.866 - RAG072592A 17.268: HG-33044-19-60-A-39, 2019 Pass-through Entity - 93.279 - The Ohio State University; 93.853 - University of Michigan Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), 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. Condition - Out of 28 payments to subrecipients that were tested, 12 were made after the 30-calendar-day requirement, 10 and 2 from the R&D Cluster and ALN 17.268, respectively. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related solely to timeliness of payments. Context - In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 39 - 242 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - The University does have formal general accounts payable and cash disbursement processes in place; however, there are no specific controls in place to ensure that subrecipients are paid within the 30-day requirement. Although all of the payments were ultimately made, the lack of controls resulted in several late payments. Recommendation - The University should implement a control to ensure that payments are made within the required time frame. Views of Responsible Officials and Corrective Action Plan - Accounts payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expenditure. For federal award expenditures, accounts payable will manually change the payment terms to 30 calendar days or less to ensure compliance. Periodically, accounts payable will review open federal award payables to verify payment terms have been properly set for the 30-day compliance requirement. The Controller’s and Accounts Payable offices will also explore creating a more efficient long-term solution, whereby the 30-day terms could be automatically set during the purchase order creation process. This would eliminate any manual updates to the payment terms by accounts payable personnel. The Sponsored Research Services Accounting Office will send reminders to all college business officers and principal investigators (PIs) to highlight the need for prompt review and approval of federal award invoices. This language will be incorporated into the SRS Best Grant Practices training classes, as well as the University’s fundamentals of sponsored administration training courses.

Categories

Subrecipient Monitoring Procurement, Suspension & Debarment Cash Management Significant Deficiency

Other Findings in this Audit

  • 372180 2023-001
    Significant Deficiency
  • 372181 2023-001
    Significant Deficiency
  • 372182 2023-001
    Significant Deficiency
  • 372184 2023-001
    Significant Deficiency
  • 372185 2023-001
    Significant Deficiency
  • 372186 2023-001
    Significant Deficiency
  • 372187 2023-001
    Significant Deficiency
  • 372188 2023-002
    Significant Deficiency
  • 948622 2023-001
    Significant Deficiency
  • 948623 2023-001
    Significant Deficiency
  • 948624 2023-001
    Significant Deficiency
  • 948625 2023-001
    Significant Deficiency
  • 948626 2023-001
    Significant Deficiency
  • 948627 2023-001
    Significant Deficiency
  • 948628 2023-001
    Significant Deficiency
  • 948629 2023-001
    Significant Deficiency
  • 948630 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $230.18M
84.063 Federal Pell Grant Program $41.55M
93.645 Stephanie Tubbs Jones Child Welfare Services Program $8.61M
84.038 Federal Perkins Loan Program_federal Capital Contributions $5.36M
93.264 Nurse Faculty Loan Program (nflp) $2.51M
84.007 Federal Supplemental Educational Opportunity Grants $1.86M
93.398 Cancer Research Manpower $1.78M
93.361 Nursing Research $1.64M
93.351 Research Infrastructure Programs $1.60M
47.083 Integrative Activities $1.53M
17.268 H-1b Job Training Grants $1.29M
84.047 Trio_upward Bound $1.21M
84.033 Federal Work-Study Program $1.07M
20.232 Commercial Driver's License Program Improvement Grant $964,487
84.365 English Language Acquisition State Grants $948,782
93.732 Mental and Behavioral Health Education and Training Grants $743,150
93.279 Drug Abuse and Addiction Research Programs $671,952
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $540,820
81.121 Nuclear Energy Research, Development and Demonstration $514,294
47.075 Social, Behavioral, and Economic Sciences $499,013
93.632 University Centers for Excellence in Developmental Disabilities Education, Research, and Service $497,735
93.178 Nursing Workforce Diversity $432,494
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $408,568
93.145 Aids Education and Training Centers $393,722
93.364 Nursing Student Loans $388,518
93.342 Health Professions Student Loans, Including Primary Care Loans/loans for Disadvantaged Students $387,631
84.044 Trio_talent Search $351,709
93.103 Food and Drug Administration_research $289,246
84.042 Trio_student Support Services $279,211
93.359 Nurse Education, Practice Quality and Retention Grants $276,400
93.211 Telehealth Programs $276,177
12.900 Language Grant Program $267,349
84.217 Trio_mcnair Post-Baccalaureate Achievement $260,243
84.027 Special Education_grants to States $246,877
93.879 Medical Library Assistance $238,396
93.360 Biomedical Advanced Research and Development Authority (barda), Biodefense Medical Countermeasure Development $235,182
93.884 Grants for Primary Care Training and Enhancement $233,496
17.502 Occupational Safety and Health_susan Harwood Training Grants $224,042
27.011 Intergovernmental Personnel Act (ipa) Mobility Program $222,980
93.394 Cancer Detection and Diagnosis Research $214,886
93.839 Blood Diseases and Resources Research $188,279
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $187,786
11.609 Measurement and Engineering Research and Standards $180,569
93.162 National Health Service Corps Loan Repayment $172,528
93.262 Occupational Safety and Health Program $171,208
16.817 Byrne Criminal Justice Innovation Program $163,342
93.173 Research Related to Deafness and Communication Disorders $157,863
93.077 Family Smoking Prevention and Tobacco Control Act Regulatory Research $150,899
81.089 Fossil Energy Research and Development $142,981
93.113 Environmental Health $134,358
12.300 Basic and Applied Scientific Research $133,590
84.116 Fund for the Improvement of Postsecondary Education $130,043
93.850 Improving Epilepsy Programs, Services, and Outcomes Through National Partnerships $129,729
84.336 Teacher Quality Partnership Grants $128,125
93.136 Injury Prevention and Control Research and State and Community Based Programs $125,486
93.838 Lung Diseases Research $121,631
11.619 Arrangements for Interdisciplinary Research Infrastructure $120,565
77.008 U.s. Nuclear Regulatory Commission Scholarship and Fellowship Program $117,562
93.859 Biomedical Research and Research Training $116,321
93.667 Social Services Block Grant $110,738
93.926 Healthy Start Initiative $106,740
93.396 Cancer Biology Research $104,103
81.087 Renewable Energy Research and Development $103,923
66.511 Office of Research and Development Consolidated Research/training/fellowships $102,991
93.865 Child Health and Human Development Extramural Research $99,970
47.076 Education and Human Resources $93,896
93.226 Research on Healthcare Costs, Quality and Outcomes $93,791
93.104 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (sed) $90,799
84.229 Language Resource Centers $86,524
93.250 Geriatric Academic Career Awards Department of Health and Human Services (b) $81,857
93.143 Niehs Superfund Hazardous Substances_basic Research and Education $81,589
47.070 Computer and Information Science and Engineering $79,375
84.425 Covid-19 - Education Stabilization Fund $79,270
94.026 National Service and Civic Engagement Research Competition $74,564
93.350 National Center for Advancing Translational Sciences $72,550
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $71,129
81.086 Conservation Research and Development $67,920
47.084 Technology, Innovation, and Partnerships $63,236
12.903 Gencyber Grants Program $63,184
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $62,244
84.325 Special Education - Personnel Development to Improve Services and Results for Children with Disabilities $59,208
93.600 Head Start $58,900
93.142 Niehs Hazardous Waste Worker Health and Safety Training $58,160
85.002 McC Foreign Assistance for Overseas Programs $56,857
93.310 Trans-Nih Research Support $53,775
81.049 Office of Science Financial Assistance Program $52,238
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $50,635
84.367 Improving Teacher Quality State Grants $49,618
43.RD National Aeronautics and Space Administration $47,999
84.287 Twenty-First Century Community Learning Centers $47,966
93.840 Translation and Implementation Science Research for Heart, Lung, Blood Diseases, and Sleep Disorders $46,826
84.326 Special Education_technical Assistance and Dissemination to Improve Services and Results for Children with Disabilities $46,398
15.605 Sport Fish Restoration Program $45,152
93.242 Mental Health Research Grants $44,700
47.084 Nsf Technology, Innovation, and Partnerships $44,364
93.124 Nurse Anesthetist Traineeships $43,146
21.019 Covid-19 - Coronavirus Relief Fund $42,254
10.558 Child and Adult Care Food Program $41,061
16.812 Second Chance Act Reentry Initiative $40,979
15.611 Wildlife Restoration and Basic Hunter Education $38,725
84.323 Special Education - State Personnel Development $37,600
20.205 Highway Planning and Construction $36,267
16.738 Edward Byrne Memorial Justice Assistance Grant Program $36,262
93.940 Hiv Prevention Activities_health Department Based $33,857
93.989 International Research and Research Training $32,415
20.RD Department of Transportation $30,339
12.340 Naval Medical Research and Development $30,262
15.684 White-Nose Syndrome National Response Implementation $29,886
12.431 Basic Scientific Research $27,963
47.041 Engineering $26,652
93.107 Area Health Education Centers Point of Service Maintenance and Enhancement Awards $26,566
45.312 National Leadership Grants $26,375
43.003 Exploration $26,153
93.273 Alcohol Research Programs $23,605
20.108 Aviation Research Grants $23,405
20.200 Highway Research and Development Program $22,398
23.002 Appalachian Area Development $21,623
93.307 Minority Health and Health Disparities Research $19,958
10.225 Community Food Projects $19,890
93.908 Nurse Corps Loan Repayment Program $19,264
66.516 P3 Award: National Student Design Competition for Sustainability $18,254
84.010 Title I Grants to Local Educational Agencies $18,147
93.959 Block Grants for Prevention and Treatment of Substance Abuse $17,058
16.550 State Justice Statistics Program for Statistical Analysis Centers $16,845
15.810 National Cooperative Geologic Mapping Program $15,759
16.540 Juvenile Justice and Delinquency Prevention_allocation to States $15,263
12.800 Air Force Defense Research Sciences Program $15,000
47.074 Biological Sciences $14,773
93.080 Blood Disorder Program: Prevention, Surveillance, and Research $13,860
16.831 Children of Incarcerated Parents $13,528
93.135 Centers for Research and Demonstration for Health Promotion and Disease Prevention $13,055
93.172 Human Genome Research $12,557
87.RD Consumer Product Safety Commission $12,292
15.506 Water Desalination Research and Development Program $12,117
93.110 Maternal and Child Health Federal Consolidated Programs $11,041
93.866 Aging Research $10,729
81.RD Department of Energy $10,001
93.788 Opioid Str $9,885
97.137 Department of Homeland Security (dhs) $7,682
43.012 Space Technology $7,623
45.129 Promotion of the Humanities_federal/state Partnership $7,477
15.922 Native American Graves Protection and Repatriation Act $6,709
12.RD Department of Defense $5,919
93.318 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security $5,723
84.374 Teacher Incentive Fund $5,706
66.RD Environmental Protection Agency $5,541
12.902 Information Security Grants $5,314
15.805 Assistance to State Water Resources Research Institutes $5,173
15.657 Endangered Species Conservation Ð Recovery Implementation Funds $5,164
93.855 Allergy, Immunology and Transplantation Research $3,360
20.106 Airport Improvement Program $3,000
93.943 Epidemiologic Research Studies of Acquired Immunodeficiency Syndrome (aids) and Human Immunodeficiency Virus (hiv) Infection in Selected Population Groups $2,810
93.399 Cancer Control $2,725
93.834 Capacity Building Assistance (cba) for High-Impact Hiv Prevention $2,567
43.008 Education $2,500
93.395 Cancer Treatment Research $2,309
47.049 Mathematical and Physical Sciences $2,100
93.270 Adult Viral Hepatitis Prevention and Control $1,893
84.305 Education Research, Development and Dissemination $1,832
45.024 Promotion of the Arts_grants to Organizations and Individuals $1,775
45.130 Promotion of the Humanities_challenge Grants $1,662
93.393 Cancer Cause and Prevention Research $1,552
12.630 Basic, Applied, and Advanced Research in Science and Engineering $1,465
47.050 Geosciences $1,357
12.420 Military Medical Research and Development $1,167
84.367 Teacher Incentive Fund $1,082
93.867 Vision Research $1,011
15.807 Earthquake Hazards Research Grants $939
64.RD Department of Veterans Affairs $829
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $680
43.001 Science $654
20.701 University Transportation Centers Program $468
93.575 Child Care and Development Block Grant $294
93.778 Medical Assistance Program $204
84.324 Research in Special Education $202
93.RD Department of Health and Human Services $55
15.808 U.s. Geological Survey_ Research and Data Collection $-11
84.002 Adult Education - Basic Grants to States $-42
12.910 Research and Technology Development $-46
93.121 Oral Diseases and Disorders Research $-117
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $-313
16.838 Comprehensive Opioid Abuse Site-Based Program $-537
93.600 Covid-19 Head Start $-846
16.827 Justice Reinvestment Initiative $-4,743
10.310 Agriculture and Food Research Initiative (afri) $-11,509
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $-16,119
93.837 Cardiovascular Diseases Research $-31,073