Finding Text
Assistance Listing Number, Federal Agency, and Program Name ? 93.395, U.S. Department of Health and Human Services, Cancer Treatment Research, Research and Development Cluster; 93.173, U.S. Department of Health and Human Services, Research Related to Deafness and Communication Disorders, Research and Development Cluster; 93.393, U.S. Department of Health and Human Services, Cancer Cause and Prevention Research, Targeting DNA Methylation and Cancer Epigenome, Research and Development Cluster Federal Award Identification Number and Year ? R01 CA255506, R01 CA268440, R01 DC016519, R35 CA209859 Pass through Entity ? N/A ? direct award Finding Type ? Significant deficiency Repeat Finding No Criteria ? In accordance with 45 CFR 75.305 2 (b), for nonfederal entities other than states, payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass through entity and the disbursement by the nonfederal entity whether the payment is made by electronic funds transfers, or issuance or redemption of checks, warrants, or payments by other means. In accordance with 45 CFR 75.305 (3), when the reimbursement method is used, the federal awarding agency or pass through entity must make payment within 30 calendar days after receipt of billing, unless it is believed the request to be improper. Condition ? Controls in place did not minimize the time elapsing between the transfer of funds and disbursement to VAIA?s subrecipients. Questioned Costs None Identification of How Questioned Costs Were Computed ? Not applicable as there are no questioned costs. Context ? In 4 out of 7 transactions sampled for testing, it took VAIA greater than 30 calendar days to make payment to a subrecipient after receipt of billing. Cause and Effect ? For a period of the year, the controls in place were not followed in the normal timeline, resulting in VAIA not making payments within 30 calendar days to its subrecipients, after receipt of billing. It took VAIA between 41 and 75 days to make payment to its subrecipients. Late payments could impact the subrecipients abilities to continue the programmatic activities if not paid timely. Recommendation ? We recommend that VAIA review its procedures and controls to ensure disbursement of funds to its subrecipients is consistent with laws and regulations. Views of Responsible Officials and Corrective Action Plan Prior to the auditor?s testing that resulted in this finding, the Office of Sponsored Research (OSR) had created a new Sponsored Research Administrator role dedicated, in part, to proactive subrecipient monitoring and invoicing. This individual reports directly to the Director of Sponsored Research and meets with the Director monthly to monitor the subaward invoicing and routing process. Subaward invoicing activities were fully transitioned to the Sponsored Research Administrator (SRA) in October 2022. As part of the transition to this new SRA role, existing subaward checklists and process documentation were reviewed and improved. OSR also updated the subrecipient payment process document to include an explicit statement indicating invoices must be paid within 30 days of receipt unless the invoice is reasonably believed to be improper. Additional planned corrective actions include: - Further refining policies and procedures and roles and responsibilities related to subrecipient monitoring and invoice payments. - Implementing a formal backup plan for subrecipient payments to ensure timely payment during the absence or work overload of the SRA. - Weekly reporting on subaward invoices and payments by the SRA to OSR leadership. - Updating OSR?s invoice tracking tools to include `Invoice Date ? Received? and `Invoice Date ? Paid? fields to highlight aged invoices and enable expedited resolution plans. - Providing continuing education for the OSR team on subrecipient compliance and regulatory timelines.