FAC Explorer

Finding 580987 (2023-001)

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Requirement
M
Questioned Costs
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Year
2023
Accepted
2023-12-15
Audit: 7014
Organization: Trustees of Tufts College D/b/a Tufts University (MA)
Auditor: Pricewaterhousecoopers LLP

AI Summary

  • Core Issue: Inconsistent review of subrecipient Uniform Guidance reports for monitoring, with some reports not reviewed for over a year.
  • Impacted Requirements: Non-compliance with 2 CFR 200.332(d) and (f) regarding timely monitoring and documentation of subrecipient audits.
  • Recommended Follow-up: Revise policies to ensure annual reviews of all subrecipient reports and implement a formal secondary sign-off on risk assessment forms.

Finding Text

2023-001 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: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While 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 not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. 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 Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. 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. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. 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 Loan $191.39M
97.036 Covid-19 Disaster Grants - Public Assistance (presidentially Declared Disasters) $22.61M
93.342 Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students (hpsl/pcl/lds) - Outstanding Loans @ July 1, 2022 $9.99M
84.063 Federal Pell Grant Program $4.39M
84.038 Federal Perkins Loan - Oustanding Loans @ July 1, 2022 $3.58M
10.310 Agriculture and Food Research Initiative (afri) $2.80M
84.033 Federal Work-Study Program $2.56M
93.342 Health Professions Student Loans, Including Primary Care Loans/loans for Disadvantaged Students - New Loans Issued During 2023 $2.37M
93.351 Research Infrastructure Programs $1.83M
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $1.63M
84.032L Federal Family Education Loan - Oustanding Loans @ July 1, 2022 $1.37M
93.307 Minority Health and Health Disparities Research $1.37M
93.498 Covid-19 - Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $1.30M
93.173 Research Related to Deafness and Communication Disorders $841,214
98.007 Food for Peace Development Assistance Program (dap) $666,105
84.411C Education Innovation and Research (formerly Investing in Innovation (i3) Fund) $658,155
84.007 Federal Supplemental Education Opportunity Grants $606,489
93.242 Mental Health Research Grants $551,568
98.001 Usaid Foreign Assistance for Programs Overseas $421,072
43.007 Space Operations $379,253
98.001 Usaid Foreign Assistance for Programs Overseas-One Health Workforce $355,339
10.253 Consumer Data and Nutrition Research $340,661
47.074 Biological Sciences $331,189
93.516 Public Health Training Centers Program $327,691
12.300 Basic and Applied Scientific Research $323,549
12.431 Basic Scientific Research $305,675
14.900 Lead-Based Paint Hazard Control in Privately-Owned Housing $297,111
93.838 Lung Diseases Research $291,922
93.732 Mental and Behavioral Health Education and Training Grants $282,777
93.866 Aging Research $266,789
20.200 Highway Research and Development Program $241,012
81.124 Predictive Science Academic Alliance Program $201,691
81.RD Department of Energy Contract $197,706
12.750 Uniformed Services University Medical Research Projects $182,499
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $170,210
12.RD Air Force Research Laboratory $164,859
20.109 Air Transportation Centers of Excellence $157,985
10.443 Outreach and Assistance for Socially Disadvantaged and Veteran Farmers and Ranchers $152,363
43.001 Science $149,535
12.RD Defense Advanced Research Projects Agency $147,821
93.855 Allergy and Infectious Diseases Research $146,516
12.420 Military Medical Research and Development $143,019
93.839 Blood Diseases and Resources Research $141,987
19.033 Global Threat Reduction $137,480
15.807 Earthquake Hazards Program Assistance $137,262
10.175 Farmers Market and Local Food Promotion Program $131,359
47.079 Office of International Science and Engineering $128,385
93.059 Training in General, Pediatric, and Public Health Dentistry $123,223
12.630 Basic, Applied, and Advanced Research in Science and Engineering $121,754
12.RD Strategic Environmental Research and Development Program $113,681
12.800 Air Force Defense Research Sciences Program $106,619
47.075 Social, Behavioral, and Economic Sciences $97,146
10.176 Dairy Business Innovation Initiatives $94,146
10.025 Plant and Animal Disease, Pest Control, and Animal Care $93,457
47.084 Technology, Innovation, and Partnerships $88,739
12.RD Integrated Optics for Geiger-Mode Avalanche Photodetectors $85,856
93.137 Community Programs to Improve Minority Health Grant Program $84,094
93.837 Cardiovascular Diseases Research $80,660
93.353 21st Century Cures Act - Beau Biden Cancer Moonshot $78,573
81.049 Office of Science Financial Assistance Program $75,260
93.352 Construction Support $72,217
45.162 Promotion of the Humanities Teaching and Learning Resources and Curriculum Development $71,517
84.336 Mathematics and Science Partnerships $71,049
15.423 Bureau of Ocean Energy Management (boem) Environmental Studies (es) $70,367
97.067 Homeland Security Grant Program $67,594
47.050 Geosciences $65,435
10.319 Farm Business Management and Benchmarking Competitive Grants Program $65,019
93.856 Microbiology and Infectious Diseases Research $64,465
84.305 Education Research, Development and Dissemination $62,227
45.169 Promotion of the Humanities Office of Digital Humanities $62,141
10.500 Cooperative Extension Service $61,866
93.398 Cancer Research Manpower $61,587
10.328 National Food Safety Training, Education, Extension, Outreach, and Technical Assistance Competitive Grants Program $59,631
97.061 Centers for Homeland Security $59,022
93.924 Ryan White Hiv/aids Dental Reimbursement and Community Based Dental Partnership Grants $58,712
47.049 Mathematical and Physical Sciences $57,565
10.210 Higher Education – Graduate Fellowships Grant Program $56,287
93.859 Biomedical Research and Research Training $56,276
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $55,037
12.330 Science, Technology, Engineering & Mathematics (stem) Education, Outreach and Workforce Program $53,034
81.087 Renewable Energy Research and Development $51,996
93.310 Trans-Nih Research Support $51,551
10.207 Animal Health and Disease Research $50,093
10.520 Agriculture Risk Management Education Partnerships Competitive Grants Program $47,501
93.273 Alcohol Research Programs $46,132
93.877 Autism Collaboration, Accountability, Research, Education, and Support $44,664
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $42,526
10.255 Research Innovation and Development Grants in Economic (ridge) $40,443
93.989 International Research and Research Training $36,566
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) - App Cert - Snow Removal Response $36,477
93.121 Oral Diseases and Disorders Research $32,852
93.113 Environmental Health $31,093
10.902 Soil and Water Conservation $30,523
47.070 Computer and Information Science and Engineering $26,726
94.026 Corporation for National and Community Service $25,951
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $24,085
93.397 Cancer Centers Support Grants $22,427
93.279 Drug Abuse and Addiction Research Programs $18,849
43.RD Association of Universities for Research in Astronomy, INC $18,620
93.393 Cancer Cause and Prevention Research $18,487
47.076 Education and Human Resources $18,106
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $17,145
93.395 Cancer Treatment Research $17,142
93.394 Cancer Detection and Diagnosis Research $14,941
10.215 Sustainable Agriculture Research and Education $14,927
19.040 Public Diplomacy Programs $14,853
81.089 Fossil Energy Research and Development $14,026
10.377 Agriculture Innovation Center Demonstration Program $13,579
93.867 Vision Research $12,966
45.024 Promotion of the Humanities Teaching and Learning Resources and Curriculum Development $11,115
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $10,903
10.960 Technical Agricultural Assistance $10,175
45.160 Promotion of the Humanities Teaching and Learning Resources and Curriculum Development $10,000
93.226 Research on Healthcare Costs, Quality and Outcomes $9,747
93.396 Cancer Biology Research $9,663
84.330 Advanced Placement Incentive Program $9,048
10.001 Agricultural Research Basic and Applied Research $7,613
93.103 Food and Drug Administration Research $6,672
10.525 Farm and Ranch Stress Assistance Network Competitive Grants Program $6,544
81.135 Advanced Research Projects Agency - Energy $6,195
10.250 Agricultural and Rural Economic Research, Cooperative Agreements and Collaborations $5,627
93.061 Innovations in Applied Public Health Research $4,790
93.349 Packaging and Spreading Proven Pediatric Weight Management Interventions for Use by Low-Income Families $4,508
93.350 National Center for Advancing Translational Sciences $4,445
10.311 Beginning Farmer and Rancher Development Program $2,625
93.600 Head Start $2,389
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) - Cat Z - Mangement Cost $1,824
12.RD U.s. Army Medical Research Acquisition Activity $1,218
91.003 Annual Senior Fellowship Competition $556
45.312 National Leadership Grants $386
93.884 Grants for Primary Care Training and Enhancement $162
12.910 Research and Technology Development $95
93.RD Department of Health and Human Services, Contract $-1,379
47.041 Engineering $-3,091
93.865 Child Health and Human Development Extramural Research $-3,567
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $-5,393
93.213 Research and Training in Complementary and Integrative Health $-24,572