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Fraud, Abuse, Or Retaliation
Where To Report Waste Fraud, Abuse, Or Retaliation

Performance Audit of Incurred Costs – North Carolina Central University

Related Open Recommendations

Recommendation Number Recommendation Status Significant Recommendation Additional Details
1.1 Open Yes
Direct NCCU to provide documentation supporting that it has repaid or otherwise credited the $24,029 in questioned participant support, indirect, and other direct costs for which NCCU has agreed to reimburse NSF.
1.2 Open Yes
Direct NCCU to establish clear guidance regarding allowable uses of participant support cost funding. This guidance should address how to segregate and account for costs that NCCU cannot cover using participant support cost funds, such as costs incurred for NCCU employees, non-participant conference registrants, and other expenses not included in the approved participant support cost budget, including those incurred for entertainment.
1.3 Open Yes
Direct NCCU to update its internal rebudgeting processes to note that NCCU must receive express permission from NSF to rebudget funds awarded in the participant support cost budget category and to identify when and how to request NSF approval to re-budget these funds.
1.4 Open Yes
Direct NCCU to strengthen its monitoring procedures and internal control processes for applying indirect costs to federal awards. Updated procedures should ensure that NCCU only applies indirect costs to expenses that are allowable in its Modified Total Direct Cost base per federal and NCCU policies. These procedures could include: • Performing an annual review of costs incurred to benefit NSF award participants to ensure the participant support costs were charged to an account excluded from NCCU’s Modified Total Direct Cost base. • Verifying subaward costs in excess of $25,000 were charged to accounts that are excluded from NCCU’s Modified Total Direct Cost base. • Performing periodic reviews of expenses in excess of $5,000 that were charged to materials/supplies accounts to ensure any costs that should have been considered equipment are appropriately transferred to an equipment account that is excluded from NCCU’s Modified Total Direct Cost base. • Updating its indirect cost rate policies to note that costs to rent equipment are not allowable in NCCU’s Modified Total Direct Cost base, which is consistent with federal regulations.
1.5 Open Yes
Direct NCCU to strengthen its administrative and management procedures to ensure that it only charges actual expenses, and not estimated costs, to NSF awards.
2.1 Open Yes
Direct NCCU to provide documentation supporting that it has repaid or otherwise credited the $22,748 in questioned insurance, airfare, consultant services, and material and supply costs for which NCCU has agreed to reimburse NSF.
2.2 Open Yes
Direct NCCU to strengthen its policies and procedures and internal controls for allocating expenses, and for supporting the allocation of expenses, charged to sponsored projects. Updated processes could include: • Requiring Principal Investigators to review and certify the allowability and allocability of all payments made to or on behalf of NSF award participants. • Documenting how airfare and other travel expenses benefit a sponsored award prior to allocating reimbursed travel costs to NSF awards. • Requiring departmental personnel or other designated invoice approvers to confirm that invoiced consultant services align to the objectives of the award(s) the consultant costs are being charged to prior to charging consultant costs to NSF awards. • Updating NSF award close-out procedures to require a review of all material and supply purchases made within the final 90 days of a grant award’s period of performance and requiring that all costs associated with materials received after an NSF award’s expiration date be removed from the NSF award.
3.1 Open Yes
Direct NCCU to provide documentation supporting that it has repaid or otherwise credited the $13,543 in questioned inadequately supported participant support and salary and wages expenses for which NCCU has agreed to reimburse NSF.
3.2 Open Yes
Direct NCCU 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 NSF awards. Updated procedures could include requiring the following: • Departmental personnel to track the purchase and distribution of all gift cards charged to NSF awards through the use of a gift-card log, or other appropriate documentation. • Principal Investigators or other appropriate personnel to justify the amount of all NSF stipend payments that are provided at an amount not consistent with the NSF award budget. • Temporary employees to complete timesheets and/or effort certifications consistent with the requirements for full-time employees.
4.1 Open Yes
Direct NCCU to strengthen its administrative and management procedures for the annual inventory process to ensure that all capitalizable expenses are accurately accounted for, tracked, and inventoried.

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