Finding 957497 (2023-001)

Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 47.041, National Science Foundation, Engineering Grants - 93.855, U.S. Department of Health and Human Services, Allergy, Immunology and Transplantation Research - 12.910, U.S. Department of Interior, Research and Technology Development (R & D) - 12.431, U.S. Department of Defense, Basic Scientific Research Federal Award Identification Number and Year - 47.041 - 1855937-CBET - 93.855 - 5R01AI158220-02 - 12.910 - D18AC00024 - 12.431 - W52P1J-22-9-3009; W52P1J-20-9-3009-10 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a payment within 30 calendar days after receipt of the billing unless the federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition - The University did not have adequate controls in place to ensure invoices to subrecipients were paid timely within the 30-calendar-day requirement. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - There were no questioned costs identified. Context - Out of 60 payments to subrecipients that were tested related to the R&D Cluster, 8 were made after the 30-calendar-day requirement. In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 31-49 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - While the University had effective controls that were successful in achieving the 30-calendar-day requirement for 52 samples, the University failed to provide supplemental support and preventive controls during a period when it was addressing an issue that prevented timely payment for certain subrecipients. Recommendation - The University should ensure appropriate training of employees is taking place and a preventive control is implemented to ensure that payments are made within the required timeline. Views of Responsible Officials and Corrective Action Plan - Purdue University will address the recommendations and implement the following preventive controls to ensure that payments are made within the required timeline. 1. The Office of Research will increase the priority around the 30-day processing deadline mandated by the Uniform Guidance 2 FR 200.305 (b)(3). This will be accomplished through communications, training, and expectation setting with the following audiences: a. Principal investigators of active grants with sub-awards i. Blanket communication ii. Add the expected turnaround time on each subrecipient communication when seeking principal investigator review and approval b. Sub-award team in sponsored program i. Blanket communication ii. Add the expected turnaround time to the expectations document for each sub-award team member iii. Add sub-recipient payment deadlines to the mandatory training for the sub-award team iv. Update payment terms to “Payable immediately Due net; Based on Doc Date” for all subrecipient invoices 2. We will begin using the date the invoice is received at Purdue University in our financial system instead of the date on the invoice for tracking purposes. 3. Create a report for internal reporting and tracking of pending subinvoices to improve awareness of payments approaching the 30-day deadline.