Performance Audit of Incurred Costs - Duke University

Submitting OIG:

National Science Foundation OIG

Date Issued:

Monday, August 31, 2020

Agency Reviewed / Investigated:

National Science Foundation

Submitting OIG-Specific Report Number:

20-1-008

External entity, if applicable:

Duke University

Location(s):

Durham, NC

United States

Type of Report:

Audit

Questioned Costs:

$708,906

Funds for Better Use:

Number of Recommendations:

View Document:

Attachment	Size
20-1-008_Duke_University.pdf	10.84 MB

Recommendation Number	Recommendation Status	Significant Recommendation
Finding 1, Rec. 3	Open	Yes
Direct Duke to strengthen its policies and procedures related to charging project coordinator time directly to NSF awards. Updated procedures should require the award’s Principal Investigator to verify that the sponsor appropriately approved any project coordinator salaries charged directly to an NSF award, or that the effort the coordinator spent on administrative activities is appropriately segregated from time spent on programmatic activities.
Finding 1, Rec. 4	Open	Yes
Direct Duke to strengthen its policies and procedures related to purchasing airfare that will be charged to a Federal project. Updated procedures could include: a. Requiring travelers to document the business purpose of each day of a planned trip before purchasing airfare to enable Duke to evaluate whether it must perform a travel comparison to support that airfare costs did not increase as a result of personal travel. b. Requiring travelers to maintain documentation to support compliance with the Fly America Act and, if a deviation is required, maintain documentation that supports the costs relate to an allowable Fly America Act exception. c. Requiring travelers to justify and document any conditions that resulted in an allowable need to purchase upgraded airfare, as required by Federal regulations. d. Updating its foreign travel policies to provide specific guidance regarding the allowability of business-class airfare on federally sponsored awards, including how the traveler should document the cost of comparable economy-class airfare.
Finding 1, Rec. 5	Open	Yes
Direct Duke to strengthen its controls surrounding spending on NSF awards for which the sponsor has denied no-cost extension requests.
Finding 1, Rec. 6	Open	Yes
Direct Duke to strengthen its conference hosting policies and procedures to ensure that it does not charge Federal awards for unallowable entertainment expenses, including those incurred to host evening receptions that are not necessary to achieve award objectives.
Finding 1, Rec. 7	Open	Yes
Direct Duke to strengthen its administrative and management processes and procedures related to the use of, and the re-budgeting of, participant support cost funding. Updated processes could include: a. Performing periodic reviews of all costs accumulated within accounts Duke established to track participant support costs to ensure that Duke used the funds to support participants, rather than Duke employees. b. Providing additional training on accounting for participant support costs. Training topics should include what type(s) of expense are allowable and when/how to request NSF approval to re-budget participant support costs.
Finding 1, Rec. 8	Open	Yes
Direct Duke to strengthen its policies and procedures related to providing salary and stipend payments to visiting scholars. Updated policies should ensure that visiting scholars do not receive payments that exceed their agreed-upon appointment amounts.
Finding 1, Rec. 9	Open	Yes
Direct Duke to perform periodic reviews of costs accumulated within its general ledger to identify and remove any duplicate expenses charged against Federal awards.
Finding 1, Rec. 10	Open	Yes
Direct Duke to strengthen its policies and procedures related to approving travel expense reports. Updated procedures could include: a. Updating its travel policies to include explicit guidance regarding whether Duke will reimburse travelers for per diem claimed on date(s) before a conference begins and/or after a conference ends. b. Implementing a control to validate the claimed per diem rates against those outlined on the Department of State website. c. Requiring travelers combining personal and business travel to submit documentation to support that combining the itineraries did not increase the cost of the trip.
Finding 1, Rec. 11	Open	Yes
Direct Duke to establish additional controls to help ensure that it appropriately creates and retains all documentation necessary to support the allowability of expenses charged to sponsored programs.
Finding 1, Rec. 12	Open	Yes
Direct Duke to implement a control to flag any charges against an NSF award when the purchaser incurs the expense more than 90 days before the effective date of an award.

Recommendation Number

Recommendation Status

Significant Recommendation

Additional Details

Finding 1, Rec. 3

Open

Yes

Direct Duke to strengthen its policies and procedures related to charging project coordinator time directly to NSF awards. Updated procedures should require the award’s Principal Investigator to verify that the sponsor appropriately approved any project coordinator salaries charged directly to an NSF award, or that the effort the coordinator spent on administrative activities is appropriately segregated from time spent on programmatic activities.

Finding 1, Rec. 4

Open

Yes

Direct Duke to strengthen its policies and procedures related to purchasing airfare that will be charged to a Federal project. Updated procedures could include: a. Requiring travelers to document the business purpose of each day of a planned trip before purchasing airfare to enable Duke to evaluate whether it must perform a travel comparison to support that airfare costs did not increase as a result of personal travel. b. Requiring travelers to maintain documentation to support compliance with the Fly America Act and, if a deviation is required, maintain documentation that supports the costs relate to an allowable Fly America Act exception. c. Requiring travelers to justify and document any conditions that resulted in an allowable need to purchase upgraded airfare, as required by Federal regulations. d. Updating its foreign travel policies to provide specific guidance regarding the allowability of business-class airfare on federally sponsored awards, including how the traveler should document the cost of comparable economy-class airfare.