Finding 963374 (2023-001)

Significant Deficiency
Requirement
C
Questioned Costs
-
Year
2023
Accepted
2024-03-28
Audit: 299251
Organization: Western Michigan University (MI)

AI Summary

  • Core Issue: The University made 3 out of 20 payments to subrecipients late, exceeding the 30-day requirement.
  • Impacted Requirements: Payments must be made within 30 calendar days as per 2 CFR 200.305(b)(3).
  • Recommended Follow-Up: Implement controls to ensure timely payments and conduct training for departments on invoice submission and payment timelines.

Finding Text

Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster, 47.076, National Science Foundation, Education and Human Resources Federal Award Identification Number and Year - 1841783 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 - Out of 20 payments to subrecipients that were tested, 3 were made after the 30 calendar day requirement. Questioned Costs - None Identification of How Questioned Costs Were Computed - The issue identified was related solely to timeliness of payments. Context - In all samples tested, payment was made to the subrecipient; however, the delayed payments on 3 samples ranged from 37 - 71 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - The University does have formal general accounts payable and cash disbursement processes in place; however, there are no specific controls in place to ensure that subrecipients are paid within the 30-day requirement. Although all of the payments were ultimately made, the lack of controls resulted in several late payments. Recommendation - The University should implement a control to ensure that payments are made within the required time frame. Views of Responsible Officials and Corrective Action Plan - Management agrees. The University has established subrecipient monitoring procedures. Included in those procedures is the control to monitor the 30 day payment requirement. 2 of the payments were during the major service disruption of the entire university network. We have now implemented weekly backups to the network folders that contain our subrecipient monitoring files. 1 of the payments was due to the department not sending us the invoice timely. We plan to do follow up trainings to educate departments and PIs on the requirement for providing payment within 30 days of receipt of invoice to assure payment is made within the 30 day requirement.

Categories

Subrecipient Monitoring Cash Management Significant Deficiency

Other Findings in this Audit

  • 386932 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $91.93M
84.063 Federal Pell Grant Program $17.73M
84.215 Fund for the Improvement of Education $4.08M
84.038 Federal Perkins Loan Program $2.73M
84.336 Teacher Quality Partnership Grants $1.16M
84.007 Federal Supplemental Educational Opportunity Grants $968,538
84.423 Supporting Effective Educator Development Program $678,965
84.033 Federal Work-Study Program $546,473
84.327 Special Education_educational Technology Media, and Materials for Individuals with Disabilities $530,414
93.732 Mental and Behavioral Health Education and Training Grants $482,760
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $356,410
84.042 Trio_student Support Services $307,596
84.047 Trio_upward Bound $272,736
84.365 English Language Acquisition State Grants $190,027
84.335 Child Care Access Means Parents in School $177,780
84.149 Migrant Education_college Assistance Migrant Program $165,265
81.087 Renewable Energy Research and Development $149,051
84.116 Fund for the Improvement of Postsecondary Education $138,181
43.012 Space Technology $137,997
84.129 Rehabilitation Long-Term Training $133,857
84.325 Special Education - Personnel Development to Improve Services and Results for Children with Disabilities $132,394
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $129,308
59.037 Small Business Development Centers $124,374
12.420 Military Medical Research and Development $114,054
15.810 National Cooperative Geologic Mapping Program $91,029
47.070 Computer and Information Science and Engineering $82,717
93.867 Vision Research $81,383
93.855 Allergy, Immunology and Transplantation Research $78,696
93.865 Child Health and Human Development Extramural Research $68,738
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $64,924
84.031 Higher Education_institutional Aid $63,663
43.001 Science $62,166
81.086 Conservation Research and Development $55,498
47.075 Social, Behavioral, and Economic Sciences $49,035
93.173 Research Related to Deafness and Communication Disorders $36,689
47.084 Technology, Innovation, and Partnerships $33,445
81.U01 Other Programs: Aln Not Identified $32,155
15.662 Great Lakes Restoration $31,488
47.076 Education and Human Resources $30,997
12.800 Air Force Defense Research Sciences Program $29,960
12.750 Uniformed Services University Medical Research Projects $28,274
45.162 Promotion of the Humanities_teaching and Learning Resources and Curriculum Development $27,209
93.926 Healthy Start Initiative $27,067
93.136 Injury Prevention and Control Research and State and Community Based Programs $26,534
93.859 Biomedical Research and Research Training $26,531
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $25,637
93.110 Maternal and Child Health Federal Consolidated Programs $24,944
20.109 Air Transportation Centers of Excellence $24,010
15.808 U.s. Geological Survey_ Research and Data Collection $20,943
15.657 Endangered Species Conservation Ð Recovery Implementation Funds $20,472
16.585 Drug Court Discretionary Grant Program $18,769
98.001 Usaid Foreign Assistance for Programs Overseas $18,030
93.279 Drug Abuse and Addiction Research Programs $17,817
11.419 Coastal Zone Management Administration Awards $15,470
47.049 Mathematical and Physical Sciences $14,592
93.994 Maternal and Child Health Services Block Grant to the States $10,962
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $8,981
81.049 Office of Science Financial Assistance Program $8,961
20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research $7,654
47.041 Engineering $6,584
81.089 Fossil Energy Research and Development $4,941
93.991 Preventive Health and Health Services Block Grant $4,936
15.814 National Geological and Geophysical Data Preservation Program $3,255
10.215 Sustainable Agriculture Research and Education $3,001
47.050 Geosciences $2,488
47.074 Biological Sciences $2,171
43.008 Education $1,504
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $1,404
45.129 Promotion of the Humanities_federal/state Partnership $1,123
15.073 Earth Mapping Resources Initiative $722