Finding 525015 (2024-003)

Special Tests and Provisions – Key Personnel Research and Development Cluster, Assistance Listing Number: 84.031S Federal Granting Agency: U.S. Department of Education Program Year 2023–2024 Award No. PP031S220202-23 Type of Finding: Other Instance of Noncompliance and Deficiency Criteria: Special Test - Key Personnel-Applications/proposals or awards may include staffing proposals that specify individuals who will work on the project and the extent of the planned involvement of personnel. The nonfederal entity may change the staffing mix and level of involvement within limits specified by agency policy or in the award, but may be required to obtain federal awarding agency approval of changes in key personnel (as identified in the award, which may differ from the nonfederal entity’s designation in the application/proposal) and changes in the project director’s time commitment/level of participation in the project (OMB Circular A-110 §§_.25(c)(2) and (3)/2 CFR Sections 200.308(b)(2) and (3)). Condition: Federal regulations provide that the University is responsible for ensuring the staffing mix and level of involvement is within limits specified by agency policy or in the award, and to obtain federal awarding agency approval of changes in key personnel. The University’s internal control system did not prevent or detect that key personnel did not complete personal activity reports to support their involvement in the project as required. Questioned Costs: None Context: Out of a population of 13 key personnel assigned to the grants, a sample of four key personnel were selected for testing. One out of the four key personnel did not have formal documentation related to charging their time to the project. Our sampling method was not, and was not intended to be, statistically valid. Effect: Management failed to perform effective control activities to appropriately reduce the risk of noncompliance related to the key personnel special test during the fiscal year. The lack of an adequate control environment over this special test requirement could result in personnel being involved in projects utilizing federal funds that have not been properly approved by the granting agency. Cause: The University’s processes did not ensure that key personnel were properly involved in projects under the Research and Development Cluster. Report Finding: No Recommendation: We recommend the University strengthen its processes and controls to help ensure that all key personnel involved in projects under the Research and Development Cluster are properly approved and involved in grant project objectives. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and recommendation. See further information on the corrective action plan provided by management.