Finding Text
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.