Performance Audit of Incurred Costs– BSCS Science Learning

Submitting OIG:

National Science Foundation OIG

Date Issued:

Tuesday, June 28, 2022

Agency Reviewed / Investigated:

National Science Foundation

Submitting OIG-Specific Report Number:

22-1-009

External entity, if applicable:

BSCS Science Learning

Location(s):

Colorado Springs, CO

United States

Type of Report:

Audit

Questioned Costs:

$158,050

Funds for Better Use:

Number of Recommendations:

View Document:

Attachment	Size
22-1-009-BSCS-Science-Learning.pdf	1.86 MB

Recommendation Number	Recommendation Status	Significant Recommendation
1.1	Open	Yes
Resolve the $117,804 in questioned indirect costs, travel allowances, and gift card expenses for which BSCS has not agreed to reimburse NSF and direct BSCS to repay or otherwise remove the sustained questioned costs from its NSF award.
1.2	Open	Yes
Direct BSCS to strengthen its monitoring procedures and internal control processes for applying indirect costs to federal awards. Updated procedures could include: • Documenting the negotiation of indirect cost rates applied by subawardees that do not have federally negotiated indirect cost rates. • Establishing a process to manually adjust the application of indirect cost rates at the time BSCS receives a final negotiated rate for that period.
1.3	Open	Yes
Direct BSCS to identify all NSF awards impacted by its incorrect usage of its provisional indirect cost rate in fiscal year 2018 that were not included within the audit scope and provide NSF with evidence supporting its calculation of the total amount of indirect costs it over-applied to those NSF awards in FY 2018.
1.4	Open	Yes
Direct BSCS to identify and remove all unquestioned travel allowances charged to the sampled NSF awards, up through the discontinuation of the travel allowance program. • Upon identifying these travel allowances, BSCS should provide its analysis and the amount of the reimbursement to NSF’s Resolution and Advanced Monitoring team.
1.5	Open	Yes
Direct BSCS to strengthen its administrative and management procedures surrounding the reimbursement of unused gift cards to ensure that it appropriately credits the original funding source(s) charged for all costs associated with unused gift cards.
2.1	Open	Yes
Resolve the $39,912 in questioned inadequately supported consultant and participant support expenses for which BSCS has not agreed to reimburse NSF and direct BSCS to repay or otherwise remove the sustained questioned costs from its NSF awards.
2.2	Open	Yes
Direct BSCS to strengthen its policies and procedures for creating and retaining documentation, including introducing additional controls to help ensure that it appropriately creates and maintains all documentation necessary to support the allowability of expenses charged to sponsored programs. Updated procedures could include: • Requiring confirmation that an active consultant service agreement is in place before paying a consultant service invoice. • Establishing tracking documentation for gift cards charged as participant support costs. This documentation would include the information necessary to identify who received the gift cards and when.
3.1	Open	Yes
Resolve the $334 in questioned salary expenses for which BSCS has not agreed to reimburse NSF and direct BSCS to repay or otherwise remove the sustained questioned costs from its NSF award.
3.2	Open	Yes
Direct BSCS to strengthen its administrative and management procedures and internal controls to ensure it allocates salary costs in a manner that is consistent with the employee’s effort report. Updated procedures could include verifying the amount allocated to each award is explicitly supported by the percentage allocation on the effort report.
4.1	Open	Yes
Direct BSCS to strengthen its administrative and management procedures and internal controls regarding the requirements for issuing subawards to ensure compliance with federal regulations. Updated procedures could include: $0 • Revising its policies to require personnel to evaluate subawardee risk of noncompliance in accordance with 2 Code of Federal Regulations 200.331, Requirements for pass-through entities. • Performing a risk assessment of subawardees before executing a subaward agreement, including periodically updating the original risk assessment. • Performing continuous monitoring of the subawardee based on the established level of risk determined in the latest risk assessment. • Performing a suspension/debarment review before executing a subaward agreement. • Reviewing the subawardee’s annual Single Audit in support of the risk assessment and continuous monitoring. • Reviewing and approving the subawardee’s indirect cost rate prior to the subawardee beginning work.

Recommendation Number

Recommendation Status

Significant Recommendation

Additional Details

1.1

Open

Yes

Resolve the $117,804 in questioned indirect costs, travel allowances, and gift card expenses for which BSCS has not agreed to reimburse NSF and direct BSCS to repay or otherwise remove the sustained questioned costs from its NSF award.

1.2

Open

Yes

Direct BSCS to strengthen its monitoring procedures and internal control processes for applying indirect costs to federal awards. Updated procedures could include: • Documenting the negotiation of indirect cost rates applied by subawardees that do not have federally negotiated indirect cost rates. • Establishing a process to manually adjust the application of indirect cost rates at the time BSCS receives a final negotiated rate for that period.