Finding 611701 (2022-001)

-
Requirement
B
Questioned Costs
$1
Year
2022
Accepted
2023-03-05
Audit: 24634
Organization: Washington University (MO)

AI Summary

  • Core Issue: Indirect costs on subawards were incorrectly charged, totaling $3,497,981.57, due to ERP system transition issues.
  • Impacted Requirements: Compliance with 2 CFR part 200 regarding the application of negotiated indirect cost rates was not maintained.
  • Recommended Follow-Up: Conduct a thorough review of all sponsored programs to ensure accurate indirect cost application and promptly correct any errors, including issuing refunds to sponsors.

Finding Text

Finding 2022-001 Allowable costs/cost principles Grantor: Various Program: Research and Development Cluster Assistance Listing#: Various Award Title: Various Award Year: 07/1/2021 ? 06/30/2022 Award Number: Various Pass-through Number: Various Criteria 2 CFR part 200 and 2 CFR part 200, Appendix III which requires entities to ensure that the negotiated (or submitted) indirect cost rates are correctly applied to the appropriate distribution base to arrive at allowable indirect costs that may be charged to a sponsored award. Condition During fiscal year 2022, management identified several instances where indirect costs on subawards were not appropriately charged to the sponsor. The error totaled $3,497,981.57, of which $3,475,522.68 is related to the Research and Development Cluster and the remaining $22,458.89 is related to other federal programs. Cause The University transitioned to a new ERP system at the beginning of the fiscal year. Certain subaward parameters that prevented charging sponsored awards in excess of allowable indirect costs amounts were not consistently established in the new ERP system. Effect Indirect costs in excess of the allowable amounts were charged to certain federal awards. Questioned Costs The total questioned costs associated with this finding are $3,497,981.57. As of June 30, 2022, $98.79 had been corrected in the ERP system and the associated funds were remitted back to the sponsor. The remaining items totaling $3,497,882.78 have been corrected during fiscal year 2023 along with any remaining funds requiring remittance to the sponsor. Recommendation Management should perform a review of all sponsored programs involving subawards to ensure the indirect cost rate along with any limitations associated with charging indirect costs are completely and accurately captured in the ERP system. Any errors identified should be promptly corrected and refunds should be remitted to the sponsor for instances where the sponsor was over charged for indirect costs. Management?s View and Corrective Action Plan Please refer to management?s corrective action plan for management?s response and corrective action related to this finding.

Categories

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $99.47M
84.038 Federal Perkins Loans $10.48M
84.425E Covid19-Higher Education Emergency Relief Fund - Student Aid Portion $6.94M
93.398 Cancer Research Manpower $4.98M
12.RD Military Medical Research and Development $2.64M
84.425F Covid19-Higher Education Emergency Relief Fund - Institutional Aid Portion $1.48M
84.033 Federal Work-Study Program $1.48M
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $1.47M
84.007 Federal Supplemental Educational Opportunity Grants $1.40M
93.135 Centers for Research and Demonstration for Health Promotion and Disease Prevention $1.04M
93.U16 Covid19-Biomedical Advanced Research and Development Authority (barda), Biodefense Medical Countermeasure Development $798,738
93.310 Covid19-Trans-Nih Research Support $782,505
93.365 Sickle Cell Treatment Demonstration Program $781,187
47.041 Engineering $748,349
93.834 Capacity Building Assistance (cba) for High-Impact Hiv Prevention $744,147
93.866 Covid19-Aging Research $729,473
93.732 Mental and Behavioral Health Education and Training Grants $720,708
93.233 National Center on Sleep Disorders Research $686,259
93.RD Covid19-National Cancer Institute $652,471
93.310 Trans-Nih Research Support $647,419
93.349 Childhood Obesity Research Demonstration $579,926
93.978 Preventive Health Services_sexually Transmitted Diseases Research, Demonstrations, and Public Information and Education Grants $539,125
93.U03 Centers for Disease Control and Prevention $490,039
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $485,148
43.012 Space Technology $455,487
12.351 Basic Scientific Research - Combating Weapons of Mass Destruction $452,033
84.325 Special Education - Personnel Development to Improve Services and Results for Children with Disabilities $407,954
93.917 Hiv Care Formula Grants $385,837
66.509 Science to Achieve Results (star) Research Program $380,422
81.135 Advanced Research Projects Agency - Energy $375,911
93.998 Autism and Other Developmental Disabilities, Surveillance, Research, and Prevention $370,616
93.242 Mental Health Research Grants $367,388
12.RD Defense Advanced Research Projects Agency $343,362
12.300 Basic and Applied Scientific Research $330,282
93.RD Covid19-Centers for Disease Control $328,146
93.928 Special Projects of National Significance $314,931
93.283 Centers for Disease Control and Prevention_investigations and Technical Assistance $304,755
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $303,347
12.910 Research and Technology Development $295,652
19.522 Overseas Refugee Assistance Programs for Strategic Global Priorities $284,685
93.RD Centers for Disease Control $276,896
93.RD Covid19-National Heart, Lung and Blood Institute $275,847
84.042 Trio_student Support Services $254,579
93.778 Medical Assistance Program $236,083
98.001 Usaid Foreign Assistance for Programs Overseas $230,901
93.866 Aging Research $223,290
93.084 Prevention of Disease, Disability, and Death by Infectious Diseases $216,895
93.788 Opioid Str $197,822
12.RD Department of Defense $190,374
93.RD National Heart, Lung and Blood Institute $189,553
43.007 Space Operations $189,034
93.U09 Food and Drug Administration $186,181
64.RD Department of Veterans Affairs $186,155
93.217 Family Planning_services $179,092
93.213 Research and Training in Complementary and Integrative Health $178,953
93.396 Cancer Biology Research $176,310
93.084 Covid19-Prevention of Disease, Disability, and Death by Infectious Diseases $174,216
93.859 Biomedical Research and Research Training $166,456
93.393 Cancer Cause and Prevention Research $165,636
10.219 Biotechnology Risk Assessment Research $160,458
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $159,750
47.049 Mathematical and Physical Sciences $158,862
93.809 National Organizations for Chronic Disease Prevention and Health Promotion $143,322
93.840 Translation and Implementation Science Research for Heart, Lung, Blood Diseases, and Sleep Disorders $139,133
20.600 State and Community Highway Safety $133,072
93.136 Injury Prevention and Control Research and State and Community Based Programs $131,375
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $128,924
43.001 Science $126,309
47.074 Biological Sciences $123,989
93.185 Covid19-Immunization Research, Demonstration, Public Information and Education_training and Clinical Skills Improvement Projects $121,736
93.U18 Substance Abuse and Mental Health Services Administration $116,239
81.RD Department of Energy $115,536
93.273 Alcohol Research Programs $115,372
81.112 Stewardship Science Grant Program $112,140
93.RD Administration for Children and Families $111,192
93.395 Cancer Treatment Research $110,926
93.U02 Centers for Disease Control and Prevention $110,380
43.008 Education $109,062
93.RD National Institute of Allergy and Infectious Diseases $108,756
93.RD Covid19-National Institutes of Health $106,028
93.113 Environmental Health $101,322
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nations Health $100,180
93.RD National Institute of Diabetes and Digestive and Kidney Diseases $99,900
97.077 Homeland Security Research, Development, Testing, Evaluation, and Demonstration of Technologies Related to Nuclear Threat Detection $99,417
93.361 Covid19-Nursing Research $98,267
12.800 Air Force Defense Research Sciences Program $96,396
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $92,062
21.008 Low Income Taxpayer Clinics $90,577
93.143 Niehs Superfund Hazardous Substances_basic Research and Education $85,937
93.173 Research Related to Deafness and Communication Disorders $82,470
12.420 Military Medical Research and Development $81,592
93.172 Human Genome Research $76,468
10.310 Agriculture and Food Research Initiative (afri) $75,914
12.U01 Military Medical Research and Development $74,817
93.855 Allergy, Immunology and Transplantation Research $72,711
93.U14 Health Resources and Services Adminstration $71,663
93.650 Accountable Health Communities $71,130
93.RD Covid19-Research on Healthcare Costs, Quality and Outcomes $68,893
93.843 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $67,830
93.262 Occupational Safety and Health Program $65,568
93.262 Centers for Disease Control and Prevention_investigations and Technical Assistance $65,199
16.582 Crime Victim Assistance/discretionary Grants $62,953
81.089 Fossil Energy Research and Development $60,314
14.906 Healthy Homes Technical Studies Grants $59,476
81.087 Renewable Energy Research and Development $58,615
12.RD Applied Research and Exploratory Development $56,234
98.RD Agency for International Development $54,246
93.839 Blood Diseases and Resources Research $53,434
93.855 Covid19-Allergy, Immunology and Transplantation Research $53,417
93.879 Medical Library Assistance $53,329
93.939 Hiv Prevention Activities_non-Governmental Organization Based $51,065
45.129 Promotion of the Humanities_federal/state Partnership $40,829
93.914 Hiv Emergency Relief Project Grants $39,920
47.076 Education and Human Resources $39,841
45.149 Promotion of the Humanities_division of Preservation and Access $39,620
20.RD National Highway Traffic Safety Administration $39,242
93.U01 Centers for Disease Control and Prevention $36,822
93.945 Assistance Programs for Chronic Disease Prevention and Control $33,440
93.121 Oral Diseases and Disorders Research $32,524
47.078 Polar Programs $31,090
93.U10 Food and Drug Administration $30,556
45.160 Promotion of the Humanities_fellowships and Stipends $30,523
93.226 Research on Healthcare Costs, Quality and Outcomes $29,961
93.279 Drug Abuse and Addiction Research Programs $29,645
47.083 Covid19-Integrative Activities $29,265
10.001 Agricultural Research_basic and Applied Research $29,230
47.041 Covid19-Engineering $27,203
12.431 Basic Scientific Research $26,998
93.103 Food and Drug Administration_research $25,472
81.U01 Department of Energy $25,117
93.127 Emergency Medical Services for Children $24,799
93.397 Cancer Centers Support Grants $24,007
19.040 Public Diplomacy Programs $22,359
93.399 Cancer Control $22,352
93.110 Maternal and Child Health Federal Consolidated Programs $22,006
93.360 Biomedical Advanced Research and Development Authority (barda), Biodefense Medical Countermeasure Development $20,594
66.RD Environmental Protection Agency $19,999
93.800 Organized Approaches to Increase Colorectal Cancer Screening $19,763
16.812 Second Chance Act Reentry Initiative $17,478
47.050 Geosciences $15,847
93.867 Vision Research $15,525
93.734 Empowering Older Adults and Adults with Disabilities Through Chronic Disease Self-Management Education Programs ? Financed by Prevention and Public Health Funds (pphf) $13,964
47.075 Social, Behavioral, and Economic Sciences $13,688
12.630 Basic, Applied, and Advanced Research in Science and Engineering $12,854
93.307 Minority Health and Health Disparities Research $11,594
93.080 Blood Disorder Program: Prevention, Surveillance, and Research $10,934
93.351 Research Infrastructure Programs $10,145
93.155 Rural Health Research Centers $9,868
93.361 Nursing Research $9,526
47.070 Computer and Information Science and Engineering $9,418
81.049 Office of Science Financial Assistance Program $7,870
93.838 Lung Diseases Research $7,718
93.989 International Research and Research Training $7,618
43.RD National Aeronautics and Space Adminstration $7,540
93.940 Hiv Prevention Activities_health Department Based $7,122
93.U07 Centers for Disease Control and Prevention $7,056
93.226 Covid19-Research on Healthcare Costs, Quality and Outcomes $7,032
93.242 Covid19-Mental Health Research Grants $6,624
84.200 Graduate Assistance in Areas of National Need $6,414
15.805 Assistance to State Water Resources Research Institutes $5,725
93.RD Department of Health and Human Services $5,054
16.123 Community-Based Violence Prevention Program $4,000
93.273 Covid19-Alcohol Research Programs $3,921
93.RD National Cancer Institute $3,671
47.079 Office of International Science and Engineering $3,450
93.073 Birth Defects and Developmental Disabilities - Prevention and Surveillance $3,176
93.U17 Substance Abuse and Mental Health Services Administration $2,902
93.837 Cardiovascular Diseases Research $2,859
93.353 21st Century Cures Act - Beau Biden Cancer Moonshot $2,756
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $2,753
93.RD Substance Abuse and Mental Health Services Administration $2,017
89.003 National Historical Publications and Records Grants $1,887
93.865 Child Health and Human Development Extramural Research $1,656
93.394 Cancer Detection and Diagnosis Research $1,564
93.763 Alzheimer?s Disease Initiative: Specialized Supportive Services Project (adi-Sss) Thru Prevention and Public Health Funds (pphf) $817
84.425 Education Stabilization Fund $578
93.314 Early Hearing Detection and Intervention Information System (ehdi-Is) Surveillance Program $560
93.838 Covid19-Lung Diseases Research $221
89.U01 National Archives and Records Administration $203
93.350 National Center for Advancing Translational Sciences $142
45.024 Promotion of the Arts_grants to Organizations and Individuals $-781
12.RD Air Force Defense Research Sciences Program $-2,277
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $-19,051
93.RD National Institutes of Health $-21,139