Finding Text
Criteria: Uniform Guidance section 200.308, Key personnel, and 200.303(a), Internal controlsCondition: Management was not able to provide sufficient documentation to evidence that certainpersonnel participated in the activities for R&D grants for which they were identified as key.Specifically, we noted certain key personnel who did not charge any time to projects for which theywere identified as key. We selected a sample of seven key personnel for testing and management wasnot able to provide sufficient documentation for six of them.Cause: Management did not have sufficient controls in place to ensure that key personnel wereworking on the applicable projects.Result: Without effective internal controls in place, there is an increased risk that materialnoncompliance may not be prevented or detected and corrected in a timely manner. In addition,management was not in compliance with the key personnel requirements.Questioned costs: None.Sampling approach: The sample was not intended to be, and was not, a statistically valid sample.Repeat finding: This finding is not a repeat of a finding in the immediately prior audit.Recommendation: We recommend that management develop and implement policies and proceduresto ensure personnel are actively participating in projects for which they are identified as key and thatthe participation of the key personnel is properly documented.Views of responsible officials: Management concurs with KPMG?s observations that sufficientdocumentation was not provided for FY22 to evidence that certain personnel participated in theactivities for R&D grants for which they were identified as key. As noted in the KPMG comments, insome instances, the project?s programmatic activity ended before the start of FY22; however, evidencewas provided upon request that time and effort were charged to the project in the prior year. In othercases, the key personnel reported in their annual programmatic report to the respective agency thatthey expended the expected effort on the project; however, the institution did not provide evidence thatthe effort was University supported.The University will work with the Ellucian Team to develop and implement the Banner Time and EffortReporting module. In addition, project key personnel, Research and Sponsored Programs (RSP), andGrants and Contracts Accounting (GCA) will hold mandatory quarterly meetings to review T&E reportsand ensure personnel is actively participating in projects for which they are identified as key and thatthe participation of the key personnel is appropriately documented.