FAC Explorer

Finding 516415 (2024-001)

- Repeat Finding
Requirement
M
Questioned Costs
-
Year
2024
Accepted
2024-12-20
Audit: 334355
Organization: Trustees of Tufts College D/b/a Tufts University (MA)
Auditor: Pricewaterhousecoopers LLP

AI Summary

  • Core Issue: The University’s subrecipient monitoring process has gaps, as 12 subrecipients were not reviewed in FY2024, despite a new annual Post-Award review being implemented.
  • Impacted Requirements: Compliance with 2 CFR 200.332(d) and (f) is at risk, as required reviews and follow-ups on subrecipient performance and financial reports were not consistently conducted.
  • Recommended Follow-Up: The University should enhance the completeness of its subrecipient monitoring by thoroughly reviewing the reports used for the consolidated analysis to ensure all subrecipients are included.

Finding Text

2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings

Categories

Subrecipient Monitoring

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $198.07M
93.350 National Center for Advancing Translational Sciences $12.80M
84.063 Federal Pell Grant Program $4.93M
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $4.19M
84.033 Federal Work-Study Program $2.85M
93.307 Minority Health and Health Disparities Research $2.76M
47.049 Mathematical and Physical Sciences $2.71M
93.342 Health Professions Student Loans, Including Primary Care Loans/loans for Disadvantaged Students $2.33M
84.038 Federal Perkins Loan $2.16M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $1.66M
93.173 Research Related to Deafness and Communication Disorders $887,459
93.395 Cancer Treatment Research $806,942
84.032L Federal Family Education Loan $744,712
84.007 Federal Supplemental Educational Opportunity Grants $641,461
47.079 Office of International Science and Engineering $606,487
93.516 Public Health Training Centers Program $525,885
93.352 Construction Support $514,495
93.059 Training in General, Pediatric, and Public Health Dentistry $452,679
93.351 Research Infrastructure Programs $438,037
93.732 Mental and Behavioral Health Education and Training Grants $413,683
98.007 Food for Peace Development Assistance Program (dap) $405,943
10.255 Research Innovation and Development Grants in Economic (ridge) $389,329
20.109 Air Transportation Centers of Excellence $361,389
47.074 Biological Sciences $358,205
12.431 Basic Scientific Research $357,156
93.226 Research on Healthcare Costs, Quality and Outcomes $341,387
93.866 Aging Research $329,507
93.838 Lung Diseases Research $297,748
10.025 Plant and Animal Disease, Pest Control, and Animal Care $278,943
97.061 Centers for Homeland Security $256,629
20.200 Highway Research and Development Program $238,020
12.RD Fluid Filled Mems $201,080
10.443 Outreach and Assistance for Socially Disadvantaged and Veteran Farmers and Ranchers $183,422
10.175 Farmers Market and Local Food Promotion Program $174,877
12.800 Air Force Defense Research Sciences Program $168,229
98.001 Usaid Foreign Assistance for Programs Overseas $166,148
45.149 Promotion of the Humanities Division of Preservation and Access $165,439
93.859 Biomedical Research and Research Training $162,597
93.137 Community Programs to Improve Minority Health Grant Program $162,296
93.959 Block Grants for Prevention and Treatment of Substance Abuse $129,739
97.067 Homeland Security Grant Program $129,490
93.273 Alcohol Research Programs $118,599
91.005 Priority Grant Competition $114,081
81.089 Fossil Energy Research and Development $108,458
94.026 Americorps National Service and Civic Engagement Research Competition 94.026 $108,353
43.007 Space Operations $105,606
93.867 Vision Research $102,675
81.124 Predictive Science Academic Alliance Program $100,354
10.328 National Food Safety Training, Education, Extension, Outreach, and Technical Assistance Competitive Grants Program $94,852
10.319 Farm Business Management and Benchmarking Competitive Grants Program $93,943
10.250 Agricultural and Rural Economic Research, Cooperative Agreements and Collaborations $87,534
15.RD U.s. Bureau of Safety and Environmental Enforcement $84,832
10.001 Agricultural Research Basic and Applied Research $81,449
12.420 Military Medical Research and Development $79,049
81.049 Office of Science Financial Assistance Program $78,470
15.807 Earthquake Hazards Program Assistance $74,730
93.RD Research, Prevention, and Education Programs on Lyme Disease in the United States $72,122
93.924 Ryan White Hiv/aids Dental Reimbursements $69,965
43.001 Science $66,590
11.459 Weather and Air Quality Research $65,088
20.RD Department of Transportation $62,073
12.RD Ccdc $61,334
47.084 Technology, Innovation, and Partnerships $59,746
10.253 Consumer Data and Nutrition Research $58,590
93.242 Mental Health Research Grants $58,196
10.215 Sustainable Agriculture Research and Education $57,847
93.870 Maternal, Infant and Early Childhood Homevisiting Grant Program $56,514
10.212 Small Business Innovation Researach $56,266
93.353 21st Century Cures Act - Beau Biden Cancer Moonshot $51,125
96.007 Social Security Research and Demonstration $50,707
93.310 Trans-Nih Research Support $47,081
47.076 Education and Human Resources $46,155
15.506 Water Desalination Research and Development $45,000
93.877 Autism Collaboration, Accountability, Research, Education, and Support (cares) Act of 2014 $44,481
93.398 Cancer Research Manpower $44,454
47.070 Computer and Information Science and Engineering $42,402
10.210 Higher Education – Graduate Fellowships Grant Program $42,359
93.283 Centers for Disease Control and Prevention Investigations and Technical Assistance $40,398
10.902 Soil and Water Conservation $37,839
10.207 Animal Health and Disease Research $35,146
10.935 Urban Agriculture and Innovative Production $34,997
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $34,655
93.899 Minority Hiv/aids Fund (mhaf) $33,784
47.050 Geosciences $33,252
93.855 Allergy and Infectious Diseases Research $32,269
45.162 Promotion of the Humanities Teaching and Learning Resources and Curriculum Development $27,630
93.397 Cancer Centers Support Grants $27,306
12.630 Basic, Applied, and Advanced Research in Science and Engineering $27,205
93.121 Oral Diseases and Disorders Research $26,508
47.041 Engineering $26,265
45.169 Promotion of the Humanities Office of Digital Humanities $25,860
45.024 Promotion of the Arts Grants to Organizations and Individuals $23,450
66.001 Air Pollution Control Program Support $23,175
93.393 Cancer Cause and Prevention Research $19,933
93.213 Research and Training in Complementary and Integrative Health $19,156
12.750 Uniformed Services University Medical Research Projects $18,823
81.087 Renewable Energy Research and Development $17,031
10.377 Agriculture Innovation Center Demonstration Program $14,141
81.RD Department of Energy Contract $13,938
64.115 Veterans Information and Assistance $13,310
93.113 Environmental Health $12,834
93.989 International Research and Research Training $12,811
47.075 Social, Behavioral, and Economic Sciences $10,538
93.865 Child Health and Human Development Extramural Research $9,092
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $8,481
93.279 Drug Abuse and Addiction Research Programs $8,239
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $7,813
93.396 Cancer Biology Research $6,483
12.RD Marine Debris Program $6,277
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $5,814
47.049 Mathematical and Physical Sciences $5,582
10.310 Agriculture and Food Research Initiative (afri) $5,285
10.525 Farm and Ranch Stress Assistance Network Competitive Grants Program $3,137
93.RD Department of Health and Human Services, Contract $2,477
12.RD Integrated Optics for Geiger-Mode Avalanche Photodetectors $1,268
10.311 Beginning Farmer and Rancher Development Program $790
10.960 Technical Agricultural Assistance $528
93.394 Cancer Detection and Diagnosis Research $436
93.136 Injury Prevention and Control Research and State and Community Based Programs $332
12.910 Research and Technology Development $271
10.520 Agriculture Risk Management Education Partnerships Competitive Grants Program $118
93.837 Cardiovascular Diseases Research $2
12.750 Uniformed Services University Medical Research Projects $-11
12.RD Defense Advanced Research Projects Agency $-457
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation�s Health $-2,097
93.839 Blood Diseases and Resources Research $-4,800
10.500 Cooperative Extension Service $-10,846
12.RD Air Force Research Laboratory $-15,016
12.300 Basic and Applied Scientific Research $-17,037
14.900 Lead-Based Paint Hazard Control in Privately-Owned Housing $-125,389