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Reports
Lincoln College of Technology’s Use of Higher Education Emergency Relief Fund Student Aid and Institutional Grants
We recommend that the Assistant Secretary for the Office of Postsecondary Education require LESC to update its written policies and procedures to contain sufficient detail to ensure that (1) all the steps necessary to verify student eligibility and distribute funds to students under the CARES Act and subsequent coronavirus legislations are addressed and completed, (2) funding determinations are adequately documented and supported in accordance with 2 C.F.R. § 200.302, and (3) students with exceptional need are prioritized in accordance with CRRSAA and ARP.
Regarding LESC’s decision to reallocate the amounts we questioned in this finding, we recommend that the Assistant Secretary for the Office of Postsecondary Education review the reallocated funds and determine whether LESC’s use of $710,274 of Lincoln’s Institutional grant funds to write off unpaid accounts receivable for students, who withdrew from the school due to coronavirus, was allowable and for the intended purposes of applicable coronavirus relief legislation.
If LESC’s reallocation of Lincoln’s Institutional grant funds is deemed unallowable, we recommend that the Assistant Secretary for the Office of Postsecondary require LESC to return to the Department the $700,155 of Lincoln’s Institutional grant funds that LESC improperly applied to credit student accounts for rent students paid to third-party landlords and the $9,838 that LESC improperly spent for subscriptions extending beyond the grant performance period and determine if these issues occurred at LESC’s other schools and take corrective action as appropriate.
We recommend that the Assistant Secretary for the Office of Postsecondary Education require LESC to incorporate in its policies and procedures the cash management requirements for minimizing the time between drawing down and disbursing Federal grant funds, including HEERF funds, maintaining the funds in an interest-bearing account, and remitting interest earned more than $500 in accordance with 2 C.F.R. § 200.305(b).
We recommend that the Assistant Secretary for the Office of Postsecondary Education determine whether LESC accurately calculated interest and properly remitted the interest returned in January 2021, in accordance with 2 C.F.R. § 200.305(b)(9).
Performance Audit of the Implementation of OMB COVID-19 Flexibilities – University of Michigan
Direct UM to provide documentation supporting that it has repaid or otherwise credited the $11,499 of questioned participant support costs for which it has agreed to reimburse NSF.
Direct UM to establish clear guidance regarding the rebudgeting of participant support cost funding. This guidance should address when and how to request approval to rebudget participant support cost funding, as well as how to document the approval.
Direct UM to update its current award set-up practices to require that, when setting up accounts established for NSF awards and/or funding supplements, personnel ensure that the accounts apply indirect costs using the rate(s) that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of the NSF award, rather than using the rate(s) included in the original Notice of Award.
Performance Audit of the Implementation of OMB COVID-19 Flexibilities – University of Central Florida
Direct UCF to provide documentation supporting that it has repaid or otherwise credited the $134 in questioned fringe benefit costs for which it has agreed to reimburse NSF.
Direct UCF to notify its Federal sponsors that its personnel have not yet certified their effort for the Fall 2019, Spring 2020, Summer 2020, and Fall 2020 semesters.
Direct UCF to require its employees to certify their effort for the Fall 2019, Spring 2020, Summer 2020, and Fall 2020 semesters and then process any cost transfers needed to ensure that UCF charged NSF for salary costs that were consistent with the effort certified.
Direct UCF to review all salary earned during June 2020 to verify that its accounting system appropriately applied fringe benefits at the correct rate and, if the accounting system did not apply fringe benefits at the correct rate, process any adjustments necessary.
Direct UCF to provide documentation supporting that it has repaid or otherwise credited the $160 of questioned participant support costs for which it has agreed to reimburse NSF.
Direct UCF to establish policies and procedures to ensure that it obtains and documents proper approval for insurance costs before charging the costs to NSF awards.
Direct UCF to establish policies and procedures to ensure that it does not apply fringe benefit rates to participant support costs that it processes through its payroll subledger.
Performance Audit of the Implementation of OMB COVID-19 Flexibilities – California Institute of Technology
Resolve the $16,351 in questioned salary expenses for which Caltech has not agreed to reimburse NSF and direct Caltech to repay or otherwise remove the sustained questioned costs from its NSF awards.
Direct Caltech to provide documentation supporting that it has repaid or otherwise credited the $418 of questioned salary expenses for which it has agreed to reimburse NSF.
Direct Caltech to strengthen its policies and procedures by retroactively establishing expiration dates on its use of the Other Paid Leave Pool on Federal awards and ensuring that these expiration dates align with the expiration dates and criteria specific to Flexibility 6 of Office of Management and Budget Memorandum M-20-17.
Resolve the $31,856 in questioned subaward expenses for which Caltech has not agreed to reimburse NSF and direct Caltech to repay or otherwise remove the sustained questioned costs from its NSF awards.
Direct Caltech to strengthen its internal control processes and procedures surrounding the transfer of significant portions of NSF-funded research to other organizations. Updated processes could include: a. Establishing procedures to verify whether the scope of work for a proposed subcontract on an NSF award is programmatic in nature before issuing the subcontract. If the scope of work is programmatic in nature, Caltech should obtain the NSF Grants Officer’s approval before issuing the subcontract. Caltech could obtain this approval either as part of the initial NSF grant proposal/budget or through a formal request to transfer the research or effort, submitted through NSF’s FastLane system. b. Requiring periodic training for Caltech personnel that are permitted to subaward, issue, or subcontract out research under NSF awards, to ensure that they request the appropriate approvals. c. Establishing procedures to confirm that Caltech personnel perform pass-through entity risk assessments to identify the appropriate monitoring procedures when Caltech awards NSF research to a pass-through entity. d. Establishing periodic monitoring procedures to ensure that Caltech appropriately assesses indirect costs on the first $25,000 invoiced by each subawardee.
Direct Caltech to provide documentation supporting that it has repaid or otherwise credited the $1,515 of questioned indirect costs for which it has agreed to reimburse NSF.
Direct Caltech to strengthen its monitoring procedures and internal control processes for applying indirect costs to Federal awards. Updated procedures could include: a. Requiring that personnel review rental expenses charged to NSF awards to assess whether the expenses included indirect costs. Specifically, Caltech should ensure the general ledger account codes it establishes to account for equipment rental charges do not apply indirect costs. b. Requiring that personnel review capitalized expenses charged to an NSF award to ensure that the capitalized amount includes all applicable costs.
Direct Caltech to quantify the total indirect costs inappropriately applied to NSF awards as a result of its rental equipment account inappropriately applying indirect costs and to reimburse NSF for the appropriate amount.
Direct Caltech to provide documentation supporting that it has repaid or otherwise credited the $581 of questioned salary and fringe costs for which it has agreed to reimburse NSF.
Direct Caltech to strengthen its administrative and management controls and processes surrounding the charging of salary to Intergovernmental Personnel Act awards. Updated processes could include requiring departmental payroll personnel to perform additional procedures to ensure that Caltech appropriately established initial salary payments, including verifying that all payments are within the Intergovernmental Personnel Act assignment dates.
Direct Caltech to update its current award set-up practices to require that, when setting up accounts established for NSF awards, personnel ensure that the accounts apply indirect costs using either the rates that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of the NSF grant award or the rates identified in the NSF award letters, as appropriate.
Performance Audit of the Implementation of OMB COVID-19 Flexibilities - University of Wisconsin - Madison
Resolve the $26,974 in questioned Award Cash Management $ervice drawdowns for which UW-Madison has not agreed to reimburse NSF and direct UW-Madison to repay or otherwise remove the sustained questioned drawdowns from its NSF awards.
Direct UW-Madison to provide documentation supporting that it has repaid or otherwise credited the $20,431 of questioned Award Cash Management $ervice drawdowns for which it has agreed to reimburse NSF.
Direct UW-Madison to update its administrative and management processes and internal control procedures surrounding the Award Cash Management $ervice procedures for awards with expiring appropriations. Updated processes could include validating that UW-Madison adequately documents that any Award Cash Management $ervice draws in excess of its actual expenses support immediate cash needs.
Direct UW-Madison to strengthen its award set-up processes and procedures to ensure it cannot charge costs to an active award if the Federal appropriations for the award have expired.
Direct UW-Madison to provide documentation supporting that it has repaid or otherwise credited the $1,593 in questioned costs for which it has agreed to reimburse NSF.
Direct UW-Madison to update its administrative and management processes and internal control procedures surrounding the Award Cash Management $ervice system to ensure that UW-Madison appropriately incorporates credits when calculating the total amount to draw down from, or return to, NSF.
Direct UW-Madison to update its current award set-up practices to require that, when setting up accounts established for NSF awards, personnel ensure that the accounts apply indirect costs using the rates that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of the NSF grant award, rather than using the rates included within the original grant proposal.
Direct UW-Madison to strengthen its Research Experience for Undergraduate award setup procedures to ensure that personnel select the appropriate indirect cost base.
Performance Audit of the Implementation of OMB COVID-19 Flexibilities - Florida State University
Direct FSU to provide documentation supporting that it has repaid or otherwise credited the $4,808 of questioned Award Cash Management $ervice drawdowns for which it has agreed to reimburse NSF.
Direct FSU to update its administrative and management processes and internal control procedures for awards with expiring appropriations. Updated processes could include: a. Validating that FSU adequately documents that any Award Cash Management $ervice draws in excess of its actual expenses support immediate cash needs. b. Ensuring that FSU’s system prohibits personnel from posting costs to an award after the award’s appropriation expires.
Direct FSU to provide documentation supporting that it has repaid or otherwise credited the $3,648 in questioned publication and other direct costs for which it has agreed to reimburse NSF.
Direct FSU to establish clear guidance regarding the allowability of publication expenses, including the need to acknowledge NSF funding sources.
Direct FSU to strengthen its grant closeout procedures to ensure that it reimburses NSF for any expenses that it determines did not benefit the NSF award(s) charged. Additional procedures should ensure that FSU refunds the NSF award(s) for any materials and supplies that it was unable to use before the award’s period of performance expired.
Direct FSU to implement additional controls to prevent personnel from directly charging NSF awards for costs charged to accounts established to accumulate expenses that are not typically allowed on Federal awards, such as credit/debit fees, unless the personnel obtain specific prior approval.
Direct FSU to provide documentation supporting that it has repaid or otherwise credited the $567 of questioned indirect costs for which it has agreed to reimburse NSF.
Direct FSU to strengthen its administrative and management processes and internal controls for applying indirect costs to Federal awards. Updated procedures could include implementing an annual review of other direct costs charged to sponsored awards that include funding for participant support costs to ensure that FSU is appropriately segregating other direct costs incurred on behalf of participants in accounts to which it does not apply indirect costs.
Performance Audit of the Implementation of OMB COVID-19 Flexibilities – Florida International University
Resolve the $1,252 in questioned Award Cash Management $ervice drawdowns for which FIU has not agreed to reimburse NSF and direct FIU to repay or otherwise remove the sustained questioned costs from its NSF awards.
Direct FIU to provide documentation supporting that it has repaid or otherwise credited the $14,167 of questioned costs for which it has agreed to reimburse NSF.
Direct FIU to update its administrative and management processes and internal control procedures surrounding the Award Cash Management $ervice for awards with expiring appropriations. Updated processes should ensure FIU appropriately documents how it calculates the final draw amounts for awards with expiring appropriations, to ensure it only uses the draws to cover costs incurred before the appropriation expired.
Direct FIU to strengthen its award set-up processes and procedures to ensure it cannot charge costs to an active award if the Federal appropriations for the award have expired.
Resolve the $791 in questioned fringe benefit costs for which FIU has not agreed to reimburse NSF and direct FIU to repay or otherwise remove the sustained questioned costs from its NSF awards.
Direct FIU to provide documentation supporting that it has repaid or otherwise credited the $5,934 of questioned promotional and salary costs for which it has agreed to reimburse NSF.
Direct FIU to establish clear guidance regarding the <span class="tx-tooltip" tabindex="0">
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of participant support cost funding. This guidance should address: a. Allowable uses of participant support cost funding. b. How to verify personnel did not apply fringe benefit rates to participant stipends or other non-salary expenses.
Direct FIU to strengthen its monitoring procedures surrounding costs charged to its NSF Research Experiences for Undergraduates programs. Updated procedures should ensure FIU charges costs associated with promotional and/or other unallowable items to nonFederal funding sources.
Direct FIU to update its current practices to ensure it only applies fringe benefits using fringe benefit rates that have been approved by its cognizant audit agency.
Performance Audit of the Implementation of OMB COVID-19 Flexibilities – State University of New York at Stony Brook
Direct Stony Brook to provide documentation supporting that it has repaid or otherwise credited the $20,530 of questioned Award Cash Management $ervice drawdowns associated with unspent funds.
Direct Stony Brook to update its administrative and management processes and internal control procedures surrounding the Award Cash Management $ervice for awards with expiring appropriations. Updated processes could include validating that Stony Brook only draws down funding based on immediate cash needs and/or adequately documents that any Award Cash Management $ervice draws in excess of its actual expenses support immediate cash needs.
Direct Stony Brook to provide documentation supporting that it has repaid or otherwise credited the $6,913 in questioned travel costs for which it has agreed to reimburse NSF.
Direct Stony Brook to provide additional guidance to ensure personnel reimburse NSF timely for cash drawn down for unused travel advances.
Direct Stony Brook to provide documentation supporting that it has repaid or otherwise credited the $3,898 in questioned travel costs for which it has agreed to reimburse NSF.
Direct Stony Brook to strengthen its monitoring procedures and internal controls surrounding the allocation of travel expenses to sponsored projects. Processes could include reviewing and assessing the allocation of all travel expenses charged to NSF awards.
Direct Stony Brook to separately track its on-campus and off-campus activities so that it can appropriately apply the approved on-campus and off-campus indirect cost rates.
Direct Stony Brook to update its current budget proposal process to eliminate the use of blended indirect cost rates.
Direct Stony Brook to update its current award set-up practices to require that, when setting up accounts established for NSF awards, personnel ensure that the accounts apply indirect costs using the rates that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of the NSF grant award, rather than using the rates included within the original grant proposal.
Direct Stony Brook to update its current award set-up practices to remove the establishment of indirect cost budget caps.
Performance Audit of the Implementation of OMB COVID-19 Flexibilities – University of New Mexico
Resolve the $17,269 in questioned unreasonable per diem, airfare, and ground transportation costs for which UNM has not agreed to reimburse NSF and direct UNM to repay or otherwise remove the sustained questioned costs from its NSF awards.
Direct UNM to strengthen its administrative and management procedures for reviewing travel expenses incurred on sponsored projects. Updated procedures could include periodic training for Principal Investigators to ensure they understand when NSF Grant Officer approval should be requested and how to appropriately document that only reasonable costs were charged to NSF awards.
Direct UNM to strengthen its policies and procedures regarding the reasonableness of per diem expenses incurred when employees are temporarily relocated for a period longer than 30 days.
Resolve the $3,613 in questioned tuition costs for which UNM has not agreed to reimburse NSF and direct UNM to repay or otherwise remove the sustained questioned costs from its NSF awards.
Direct UNM to provide documentation supporting that it has repaid or otherwise credited the $83 of questioned travel costs for which it has agreed to reimburse NSF.
Direct UNM to strengthen its controls surrounding the approval of expense reimbursements to ensure approvers appropriately verify that travelers are reimbursed at the appropriate U.S. General Services Administration per diem rate(s).
Direct UNM to strengthen its policies and procedures surrounding the use of participant support cost funding to cover tuition remission expenses. Specifically, UNM should update its current tuition remission policies and procedures to ensure that it does not use participant support costs to cover costs associated with credit hours that do not benefit student participants.
Direct UNM to update its award set-up practices to require that, when setting up accounts established for NSF awards, personnel ensure that the accounts apply indirect costs using the rates that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of the NSF grant award, rather than using the rates included within the original grant proposal.
Direct UNM to require subawardees to apply indirect costs using the rates that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of the subaward agreement, rather than using the rates included within the subaward budget and proposal.
Performance Audit of the Implementation of OMB COVID-19 Flexibilities – University of Kentucky Research Foundation
Direct UKRF to provide documentation supporting that it has repaid or otherwise credited the $33,151 of questioned materials and supplies costs for which it has agreed to reimburse NSF.
Direct UKRF to implement additional NSF grant close-out procedures that require the Principal Investigator to evaluate whether they should remove any expenses associated with unused materials and supplies from the NSF award.