Finding Text
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099 (09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2020-009 PROGRAM INCOME
Criteria
Pursuant to 2 CFR 200 for award objectives and the regulations at 2 CFR 200.307, program income is defined as “Gross income earned by the recipient that is directly generated by a supported activity or earned as a result of the federal award during the period of performance” by 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards. Program income reporting is due forty five (45) days after the end of the year. NSF requires that all cumulative program income is reported for all open grants and agreements in the current year.
Condition
Program income consists of registration fees collected for training, meetings or workshops and the proceeds from the sale of publications as a result of the federal award during the period of performance. Program income is treated as an additive to the federal funds received by CUAHSI. During a drawdown, program income reduces the amount that is requested to cover reimbursable costs through the Flexible Billing module. This allows program income to be applied to the award before a reimbursement is requested from NSF adding the value of program income received to the awarded amount. Program income reporting is due forty five (45) days after the end of the year. NSF requires that all cumulative program income is reported for all open grants and agreements in the current year. CUAHSI program income totaled $85,267 for the year ended December 31, 2020.
CUAHSI failed to submit the required Program Income Reporting Worksheet by the required deadline of forty five (45) days after the end of the year (February 15, 2021) to ensure with the program income policies in accordance with the UG for the year ended December 31, 2020.
Cause & Context
Lack of resources and detailed attention to the risks, along with circumvention of controls has resulted in weak internal controls, and conflicting or incomplete policies and procedures.
Effect
Non-compliance can lead to penalties, fines, or even termination of the contract. It may also damage CUAHSI’s reputation and future eligibility for federal funding and jeopardize CUAHSI’s ability to secure future grants or contracts from other funding agencies. Granting organizations typically prioritize funding recipients with a track record of compliance and accountability.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2019-011.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies consistent with 2 CFR 200.307.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.