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Inspector General Open Recommendations

09/29/2021 - National Science Foundation Performance Audit of Incurred Costs – University of California, San Francisco [Report Details] Audit - Open Recommendations

2.6
Direct UCSF to provide training regarding the policy requirements for salary charged to NSF awards to ensure payroll is processed timely, under the appropriate account codes, and appropriately certified.
3.1
Resolve the $14,365 in questioned, inadequately supported subaward and animal care expenses for which UCSF has not agreed to reimburse NSF and direct UCSF to repay or otherwise remove the sustained questioned costs from its NSF awards.
3.2
Direct UCSF to strengthen its policies and procedures related to creating and retaining documentation, including introducing additional controls to help ensure it appropriately creates and maintains all documentation necessary to support the allowability of expenses charged to sponsored programs. Updated procedures could include: Updating its current subaward approval procedures to ensure Principal Investigators appropriately approve invoices submitted through Intercampus Requests for Reimbursement by organizations within the University of California system; and Implementing additional procedures to ensure the rate(s) and service(s) provided by the Laboratory Animal Resource Center are appropriately documented within invoices it uses to charge expenses to federal awards.
4.1
Resolve the $8,402 in questioned indirect costs for which UCSF has not agreed to reimburse NSF and direct UCSF to repay or otherwise remove the sustained questioned costs from its NSF awards.
4.2
Direct UCSF to provide documentation supporting that it has repaid or otherwise credited the $1,352 of questioned indirect costs for which it has agreed to reimburse NSF.
4.3
Direct UCSF to strengthen its monitoring procedures and internal control processes for applying indirect costs to federal awards. Updated procedures could include: Conducting annual training regarding the treatment of materials used in the fabrication of equipment. Specifically, on determining when materials used in the fabrication of an asset should be part of the capitalized cost of an asset; Implementing an annual review process for costs charged to awards that include funding for participant support costs to ensure UCSF is appropriately segregating these expenses in accounts that it has excluded from its Modified Total Direct Cost base; and Requiring that personnel manually review purchases in excess of UCSF’s policy for assets to be capitalized to ensure assets have been appropriately capitalized and excluded from the Modified Total Direct Cost base.
5.1
Direct UCSF to strengthen its administrative and management procedures for rentals to ensure employees use Connexxus to rent vehicles, thereby ensuring the rental is covered by University of California’s rental car insurance for business travel.
5.2
Direct UCSF to strengthen its administrative and management procedures related to subaward processing to confirm subrecipient commitment forms are completed for each subawardee at the proposal stage.
5.3
Direct UCSF to strengthen its directives, procedures, and internal controls for procuring contract services on sponsored projects. Updated processes could include the following: Conducting annual training for those individuals who procure contract services, including Principal Investigators. Specifically, the training should include the following: Clarification on the documentation requirements for entering into a contract or consulting agreement, including when to use the Sole Selection & Price Reasonableness Justification Form, Federal Funds Checklist, and BearBuy Professional Services/Consulting form; An overview of the process for contracting the services of a University of California-system employee, including the requirement to complete the Temporary Interlocation or Multi-location Appointment Form. Implementing a manual review process to ensure individuals who initiate contract services complete all applicable forms required by University of California and UCSF procurement policy.
5.4
Direct UCSF to strengthen its procedures and internal controls for reviewing expense(s) eligibility for inclusion or exclusion from the Modified Total Direct Cost base.
6.1
Direct UCSF to develop and implement a control to identify when indirect cost rates change between provisional rates and newly negotiated indirect cost rates; as well as to take appropriate steps to avoid claiming unallowable indirect costs on NSF awards.
6.2
Direct UCSF to develop and implement a control to identify when indirect cost rates change between proposal submission and award date, as well as to take appropriate steps to avoid claiming unallowable indirect costs on NSF awards.

09/29/2021 - Department of Agriculture Follow-up on Smuggling Interdiction and Trade Compliance Program [Report Details] Audit - Open Recommendations

1
Revise PAA project selection procedures to include consideration for reviews of prior external audits to ensure corrective actions have been effective.
2
Define the metrics such as benchmarks and performance measures that will measure SITC’s effectiveness at meeting its mission to address prior audit Recommendation 1.
3
Develop and implement oversight procedures for SITC management and supervisors to periodically review benchmarks and performance metrics and implement corrective actions if the metrics are not being achieved to address prior audit Recommendation 2.
4
Require supervisors to periodically review SITC officers’ adherence to SITC requirements in selecting markets to visit to address prior audit Recommendations 4, 5, and 8. The supervisor reviews should include monitoring whether SITC officers perform timely follow-up market surveys at higher-risk markets and implement appropriate corrective actions, if needed.
5
Implement procedures for SITC supervisors to require compliance checks to ensure that the previously identified pathways were closed to address prior audit Recommendation 9.
6
Develop and implement written policies and procedures to support SITC’s e-commerce sales function to ensure efficiency, effectiveness, and consistency in identifying prohibited products and assessing pathways.
7
Establish routine training to support the SITC internet team in identifying prohibited product on the internet.
8
In coordination with OGC, determine the appropriate authorities required to effectively regulate e-commerce businesses. Based on OGC’s determination, implement the applicable policies to ensure SITC will be able to effectively identify buyers and sellers of prohibited products.

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