FAC Explorer

Finding 539974 (2024-001)

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Requirement
B
Questioned Costs
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Year
2024
Accepted
2025-03-28
Audit: 350193
Organization: Cornell University (NY)
Auditor: Pricewaterhousecoopers LLP

AI Summary

  • Core Issue: Weill Cornell Medicine failed to provide adequate justification and documentation for several cost transfers, particularly those over 90 days.
  • Impacted Requirements: This violates the Department of Health and Human Services and NIH policies, which require timely and well-documented cost transfers.
  • Recommended Follow-Up: Update cost transfer policies to ensure comprehensive records are maintained, and provide training to staff on proper documentation practices.

Finding Text

2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans-Plus $62.90M
84.268 Federal Direct Student Loans-Unsubsidized $47.87M
84.063 Federal Pell Grant Program $17.40M
10.511 Smith-Lever Extension Funding $8.88M
84.038 Federal Perkins Loan Program-Outstanding Loans As of July 1, 2023 $7.79M
10.203 Payments to Agricultural Experiment Stations Under the Hatch Act $7.17M
84.268 Federal Direct Student Loans-Subsidized $5.65M
93.351 Research Infrastructure Programs $4.75M
93.398 Cancer Research Manpower $3.72M
93.342 Health Professions Student Loans, Including Primary Care Loans/loans for Disadvantaged Students-Outstanding Loans As of July 1, 2023 $3.60M
10.514 Expanded Food and Nutrition Education Program $3.17M
84.033 Federal Work-Study Program $3.09M
84.007 Federal Supplemental Educational Opportunity Grants $3.09M
12.RD Department of Defense, Other $2.90M
84.015 National Resource Centers Program for Foreign Language and Area Studies Or Foreign Language and International Studies Program and Foreign Language and Area Studies Fellowship Program $1.36M
93.399 Covid-19: Cancer Control $1.34M
84.U06 Department of Education, Other $1.30M
93.353 21st Century Cures Act - Beau Biden Cancer Moonshot $1.26M
84.027 Special Education Grants to States $1.22M
81.112 Stewardship Science Grant Program $1.16M
93.235 Title V State Sexual Risk Avoidance Education (title V State Srae) Program $1.07M
66.437 Geographic Programs - Long Island Sound Program $1.01M
93.273 Alcohol Research Programs $864,061
43.012 Space Technology $830,098
10.230 Farm of the Future $781,464
20.205 Highway Planning and Construction $670,740
93.838 Covid-19: Lung Diseases Research $640,160
81.089 Fossil Energy Research and Development $635,922
93.186 National Research Service Award in Primary Care Medicine $593,447
10.163 Market Protection and Promotion $573,595
93.352 Construction Support $554,841
93.297 Teenage Pregnancy Prevention Program $554,813
84.047 Trio Upward Bound $551,619
93.342 Health Professions Student Loans, Including Primary Care Loans/loans for Disadvantaged Students $545,546
20.701 University Transportation Centers Program $496,919
84.421 Disability Innovation Fund (dif) $492,173
93.084 Prevention of Disease, Disability, and Death by Infectious Diseases $491,832
93.073 Birth Defects and Developmental Disabilities - Prevention and Surveillance $467,830
10.329 Crop Protection and Pest Management Competitive Grants Program $447,944
10.937 Partnerships for Climate-Smart Commodities $442,139
97.036 Covid-19: Disaster Grants - Public Assistance (presidentially Declared Disasters) $409,328
15.808 U.s. Geological Survey Research and Data Collection $409,238
93.145 Hiv-Related Training and Technical Assistance $369,624
10.174 Acer Access Development Program $363,495
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $357,731
12.351 Scientific Research - Combating Weapons of Mass Destruction $352,864
84.323 Special Education - State Personnel Development $341,165
10.699 Partnership Agreements $335,414
10.001 Agricultural Research Basic and Applied Research $334,335
84.217 Trio McNair Post-Baccalaureate Achievement $325,023
12.600 Community Investment $317,107
93.630 Developmental Disabilities Basic Support and Advocacy Grants $313,101
12.800 Air Force Defense Research Sciences Program $310,704
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $307,491
11.020 Cluster Grants $303,846
14.506 General Research and Technology Activity $292,274
93.855 Covid-19: Allergy and Infectious Diseases Research $280,757
81.U05 Department of Energy, Other $279,170
10.RD Department of Agriculture, Other $276,637
10.202 Cooperative Forestry Research $258,927
10.304 Food and Agriculture Defense Initiative (fadi) $255,752
15.805 Assistance to State Water Resources Research Institutes $254,138
17.720 Disability Employment Policy Development $249,398
47.041 Covid-19: Engineering $243,312
19.010 Academic Exchange Programs - Hubert H. Humphrey Fellowship Program $237,555
93.659 Adoption Assistance $230,923
10.164 Wholesale Farmers and Alternative Market Development $226,925
10.182 Pandemic Relief Activities: Local Food Purchase Agreements with States, Tribes, and Local Governments $219,719
81.087 Renewable Energy Research and Development $208,734
93.279 Covid-19: Drug Use and Addiction Research Programs $207,224
93.172 Human Genome Research $205,440
47.078 Polar Programs $204,524
10.219 Biotechnology Risk Assessment Research $200,588
47.083 Integrative Activities $199,509
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $192,677
10.333 Urban, Indoor, and Other Emerging Agricultural Production Research, Education, and Extension Initiative $192,416
47.074 Biological Sciences $187,826
84.016 Undergraduate International Studies and Foreign Language Programs $186,858
93.213 Research and Training in Complementary and Integrative Health $182,137
10.551 Supplemental Nutrition Assistance Program $181,330
15.812 Cooperative Research Units $178,799
10.309 Specialty Crop Research Initiative $174,677
10.971 Urban Agriculture and Urban County Committee Outreach, Technical Assistance, and Education $170,558
93.958 Block Grants for Community Mental Health Services $166,849
19.009 Academic Exchange Programs - Undergraduate Programs $165,325
10.516 Rural Health and Safety Education Competitive Grants Program $164,294
93.143 Niehs Superfund Hazardous Substances_basic Research and Education $163,471
10.153 Market News $162,459
93.233 National Center on Sleep Disorders Research $159,765
11.307 Economic Adjustment Assistance $154,227
81.135 Advanced Research Projects Agency - Energy $151,001
17.278 Wioa Dislocated Worker Formula Grants $150,342
47.041 Engineering $145,628
15.620 African Elephant Conservation Fund $144,744
16.575 Crime Victim Assistance $141,710
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation¿s Health $140,348
10.950 Agricultural Statistics Reports $137,085
93.121 Oral Diseases and Disorders Research $135,790
93.837 Covid-19: Cardiovascular Diseases Research $135,699
93.865 Child Health and Human Development Extramural Research $134,654
93.RD Department of Health and Human Services, Other $133,000
47.076 Covid-19: Stem Education (formerly Education and Human Resources) $130,132
10.025 Plant and Animal Disease, Pest Control, and Animal Care $129,356
17.401 International Labor Programs $127,624
11.419 Coastal Zone Management Administration Awards $122,858
64.056 Legal Services for Veterans Grants $122,798
12.431 Basic Scientific Research $122,704
97.045 Cooperating Technical Partners $121,795
93.433 Covid-19: Acl National Institute on Disability, Independent Living, and Rehabilitation Research $117,624
15.820 National and Regional Climate Adaptation Science Centers $116,781
47.070 Computer and Information Science and Engineering $112,840
84.126 Rehabilitation Services Vocational Rehabilitation Grants to States $108,896
10.210 Higher Education National Needs Graduate Fellowship Grants $108,801
11.024 Build to Scale $106,449
10.170 Covid-19: Specialty Crop Block Grant Program - Farm Bill $105,598
93.286 Covid-19: Discovery and Applied Research for Technological Innovations to Improve Human Health $103,483
15.423 Bureau of Ocean Energy Management (boem) Environmental Studies (es) $103,482
39.U04 General Services Administration, Other $103,367
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $102,382
11.609 Measurement and Engineering Research and Standards $102,013
10.902 Soil and Water Conservation $99,717
93.867 Vision Research $99,598
12.630 Basic, Applied, and Advanced Research in Science and Engineering $98,261
93.307 Minority Health and Health Disparities Research $97,665
45.163 Promotion of the Humanities Professional Development $97,613
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $97,083
39.U03 General Services Administration, Other $96,455
81.RD Department of Energy, Other $95,868
15.945 Cooperative Research and Training Programs ¿ Resources of the National Park System $88,801
47.084 Nsf Technology, Innovation, and Partnerships $88,759
11.303 Economic Development Technical Assistance $88,533
93.242 Covid-19: Mental Health Research Grants $86,567
17.U02 Department of Labor, Other $85,478
10.177 Regional Food System Partnerships $82,508
93.067 Global Aids $80,891
45.161 Promotion of the Humanities Research $79,988
93.395 Cancer Treatment Research $79,451
15.247 Wildlife Resource Management $78,821
45.313 Laura Bush 21st Century Librarian Program $77,686
12.910 Research and Technology Development $76,284
10.515 Renewable Resources Extension Act $71,676
93.157 Centers of Excellence $69,530
12.355 Pest Management and Vector Control Research $69,465
15.635 Neotropical Migratory Bird Conservation $68,989
47.049 Mathematical and Physical Sciences $68,862
84.033 Federal Work-Study Program, Administrative Allowance $68,588
66.469 Geographic Programs - Great Lakes Restoration Initiative $68,432
84.022 Overseas Programs - Doctoral Dissertation Research Abroad $66,204
84.264 Rehabilitation Training Technical Assistance Centers $65,225
93.393 Cancer Cause and Prevention Research $62,736
81.049 Office of Science Financial Assistance Program $61,917
10.162 Inspection Grading and Standardization $61,315
15.634 State Wildlife Grants $61,255
45.130 Promotion of the Humanities Challenge Grants $60,811
10.167 Transportation Services $60,498
98.RD Agency for International Development, Other $59,842
93.310 Trans-Nih Research Support $59,666
11.427 Fisheries Development and Utilization Research and Development Grants and Cooperative Agreements Program $59,447
93.250 Geriatric Academic Career Awards Department of Health and Human Services $59,335
20.600 State and Community Highway Safety $58,698
10.175 Covid-19: Farmers Market and Local Food Promotion Program $57,648
93.534 Affordable Care Act Program for Early Detection of Certain Medical Conditions Related to Environmental Health Hazards $57,226
93.113 Environmental Health $57,034
93.575 Child Care and Development Block Grant $56,379
93.839 Covid-19: Blood Diseases and Resources Research $50,793
11.459 Weather and Air Quality Research $50,090
15.655 Migratory Bird Monitoring, Assessment and Conservation $50,040
12.300 Basic and Applied Scientific Research $48,649
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $48,604
93.847 Covid-19: Diabetes, Digestive, and Kidney Diseases Extramural Research $46,564
10.310 Covid-19: Agriculture and Food Research Initiative (afri) $46,532
93.855 Allergy and Infectious Diseases Research $46,523
15.408 Bureau of Ocean Energy Management Renewable Energy $45,827
93.283 Centers for Disease Control and Prevention Investigations and Technical Assistance $45,443
93.350 National Center for Advancing Translational Sciences $42,497
81.121 Nuclear Energy Research, Development and Demonstration $40,902
15.229 Wild Horse and Burro Resource Management $40,685
10.215 Sustainable Agriculture Research and Education $39,664
97.067 Homeland Security Grant Program $39,388
98.001 Usaid Foreign Assistance for Programs Overseas $39,269
66.203 Environmental Finance Center Grants $37,876
10.500 Cooperative Extension Service $37,185
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $36,445
45.024 Promotion of the Arts Grants to Organizations and Individuals $36,390
10.290 Agricultural Market and Economic Research $36,344
19.501 Public Diplomacy Programs for Afghanistan and Pakistan $36,249
94.008 Americorps Commission Investment Fund 94.008 $36,108
10.156 Federal-State Marketing Improvement Program $36,101
15.628 Multistate Conservation Grant $35,666
93.658 Foster Care Title IV-E $35,527
93.928 Special Projects of National Significance $35,325
47.076 Stem Education (formerly Education and Human Resources) $34,188
16.582 Crime Victim Assistance/discretionary Grants $34,156
93.368 21st Century Cures Act - Precision Medicine Initiative $32,890
47.075 Covid-19: Social, Behavioral, and Economic Sciences $32,664
15.611 Wildlife Restoration and Basic Hunter Education and Safety $32,406
12.340 Naval Medical Research and Development $30,857
10.207 Animal Health and Disease Research $30,448
93.360 Covid-19: Biomedical Advanced Research and Development Authority (barda), Biodefense Medical Countermeasure Development $30,384
93.173 Research Related to Deafness and Communication Disorders $29,676
10.223 Hispanic Serving Institutions Education Grants $29,161
10.311 Beginning Farmer and Rancher Development Program $28,944
10.318 Women and Minorities in Science, Technology, Engineering, and Mathematics Fields $28,763
93.080 Blood Disorder Program: Prevention, Surveillance, and Research $28,644
43.002 Aeronautics $27,926
11.012 Integrated Ocean Observing System (ioos) $27,767
93.885 Cell and Gene Therapy (cgt) Access Model $27,136
15.647 Migratory Bird Conservation $25,654
10.028 Wildlife Services $25,339
93.866 Aging Research $25,104
21.009 Volunteer Income Tax Assistance (vita) Matching Grant Program $24,686
12.420 Covid-19: Military Medical Research and Development $24,634
93.110 Maternal and Child Health Federal Consolidated Programs $24,564
11.431 Climate and Atmospheric Research $24,205
93.859 Biomedical Research and Research Training $24,205
93.840 Translation and Implementation Science Research for Heart, Lung, Blood Diseases, and Sleep Disorders $23,289
10.170 Specialty Crop Block Grant Program - Farm Bill $23,121
19.300 Program for Study of Eastern Europe and the Independent States of the Former Soviet Union $22,197
15.670 Adaptive Science $22,018
10.331 Gus Schumacher Nutrition Incentive Program $21,723
12.420 Military Medical Research and Development $21,679
93.989 International Research and Research Training $21,460
43.RD National Aeronautics and Space Administration, Other $21,387
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $19,920
81.086 Conservation Research and Development $19,499
16.838 Comprehensive Opioid, Stimulant, and Other Substances Use Program $18,892
10.761 Water and Waste Technical Assistance and Training Grants $18,624
84.305 Education Research, Development and Dissemination $18,153
93.242 Mental Health Research Grants $17,840
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $17,815
43.001 Science $17,663
84.373 Special Education Technical Assistance on State Data Collection $17,102
93.866 Covid-19: Aging Research $17,092
10.652 Forestry Research $16,787
93.343 Public Health Service Evaluation Funds $16,002
10.320 Sun Grant Program $15,814
10.575 Farm to School Grant Program $15,704
84.063 Federal Pell Grant Program-Administrative Allowance $15,060
93.421 Covid-19: Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $15,010
84.215 Innovative Approaches to Literacy; Promise Neighborhoods; Full-Service Community Schools; and Congressionally Directed Spending for Elementary and Secondary Education Community Projects $14,751
93.396 Cancer Biology Research $14,595
47.075 Social, Behavioral, and Economic Sciences $14,270
15.637 Migratory Bird Joint Ventures $14,100
10.310 Agriculture and Food Research Initiative (afri) $13,959
15.069 Zoonotic Disease Initiative $13,310
45.169 Promotion of the Humanities Office of Digital Humanities $13,152
15.662 Great Lakes Restoration $12,939
66.716 Research, Development, Monitoring, Public Education, Outreach, Training, Demonstrations, and Studies $12,035
11.417 Covid-19: Sea Grant Support $11,736
43.008 Office of Stem Engagement (ostem) $11,729
10.307 Organic Agriculture Research and Extension Initiative $11,416
93.394 Cancer Detection and Diagnosis Research $11,319
15.923 National Center for Preservation Technology and Training $10,928
15.073 Earth Mapping Resources Initiative $10,721
10.217 Higher Education - Institution Challenge Grants Program $10,653
10.645 Farm to School State Formula Grant $10,619
19.040 Public Diplomacy Programs $10,564
15.944 Natural Resource Stewardship $10,472
93.185 Immunization Research, Demonstration, Public Information and Education Training and Clinical Skills Improvement Projects $10,265
66.950 National Environmental Education Training Program $10,183
66.516 P3 Award: National Student Design Competition for Sustainability $9,019
43.007 Space Operations $8,737
10.303 Integrated Programs $8,708
47.079 Office of International Science and Engineering $8,227
10.525 Farm and Ranch Stress Assistance Network Competitive Grants Program $7,275
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $6,745
93.310 Covid-19: Trans-Nih Research Support $6,463
93.279 Drug Use and Addiction Research Programs $6,304
10.336 Veterinary Services Grant Program $6,171
10.250 Agricultural and Rural Economic Research, Cooperative Agreements and Collaborations $5,995
10.678 Forest Stewardship Program $5,886
93.839 Blood Diseases and Resources Research $5,141
11.417 Sea Grant Support $5,004
93.837 Cardiovascular Diseases Research $5,000
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $4,921
93.395 Covid-19: Cancer Treatment Research $4,866
10.707 Research Joint Venture and Cost Reimbursable Agreements $4,836
93.226 Research on Healthcare Costs, Quality and Outcomes $4,640
10.176 Dairy Business Innovation Initiatives $4,624
10.352 Value-Added Producer Grants $4,590
10.200 Grants for Agricultural Research, Special Research Grants $4,496
93.077 Family Smoking Prevention and Tobacco Control Act Regulatory Research $3,954
10.527 New Beginning for Tribal Students $3,100
93.350 Covid-19: National Center for Advancing Translational Sciences $3,054
10.680 Forest Health Protection $2,933
93.157 Covid-19: Centers of Excellence $2,864
10.175 Farmers Market and Local Food Promotion Program $2,663
10.520 Agriculture Risk Management Education Partnerships Competitive Grants Program $2,549
16.710 Public Safety Partnership and Community Policing Grants $2,511
10.912 Environmental Quality Incentives Program $2,443
45.309 Museum Grants for African American History and Culture $2,229
10.328 Food Safety Outreach Program $1,983
10.190 Resilient Food System Infrastructure Program $1,897
47.050 Geosciences $1,804
16.726 Juvenile Mentoring Program $1,718
10.330 Alfalfa Seed and Alfalfa Forage Systems Program $1,586
10.572 Wic Farmers' Market Nutrition Program (fmnp) $1,555
11.008 Noaa Mission-Related Education Awards $1,339
93.103 Food and Drug Administration Research $617
11.432 National Oceanic and Atmospheric Administration (noaa) Cooperative Institutes $615
10.229 Extension Collaborative on Immunization Teaching & Engagement $553
45.025 Promotion of the Arts Partnership Agreements $500
93.397 Cancer Centers Support Grants $458
93.399 Cancer Control $333
93.RD Covid-19: Department of Health and Human Services, Other $204
93.879 Medical Library Assistance $156
47.RD National Science Foundation, Other $63
93.068 Chronic Diseases: Research, Control, and Prevention $-17
93.103 Covid-19: Food and Drug Administration Research $-303
93.361 Nursing Research $-506
10.U01 Department of Agriculture, Other $-668
43.003 Exploration $-3,510
93.838 Lung Diseases Research $-13,136