Audit of the Teaching with Primary Sources Program and the Three Regional Partners

What Office of Inspector General Evaluated

The objectives of this engagement were to:

• Determine compliance with the requirements for grant awards issued to Waynesburg University, Illinois State University, and Metropolitan State University of Denver.
• Determine whether these universities are administering, awarding, and monitoring subawards in compliance with the Uniform Guidance, program requirements, and their respective requirements.

What Office of Inspector General Found

• Inadequate procedures to continue Teaching with Primary Sources awards.
• Ineffective controls for indirect cost approval and monitoring.
• Non-compliance with matching requirements.

What Office of Inspector General Recommends

We recommend that the Library:

• Update its Grants and Cooperative Agreements Guidelines and Procedures to limit the number of times the Library can continue the cooperative agreements, taking into consideration subgrantees’ record retention requirements.
• Update its policies and procedures to require Contracts and Grants Directorate to perform an annual review of relevant policies and procedures (e.g., Grants and Cooperative Agreements Guidelines and Procedures and Teaching with Primary Sources Administrative Requirements), including identifying any significant changes to the process (such as incorporating indirect costs into the budget proposal) that would require Contracts and Grants Directorate to update—or develop— control activities to help ensure that the Library and the regional partners are meeting the Teaching with Primary Sources objectives and appropriately mitigating risks.
•  Update Grants and Cooperative Agreements Guidelines and Procedures to address the monitoring of indirect costs, including: 
• Adding a requirement for Contracts and Grants Directorate to review the documentation supporting the basis for any changes in a regional partner’s indirect cost rate percentage. The procedures should include how Contracts and Grants Directorate will conduct and document this review. 
• Adding periodic reviews of regional partners’ application of their indirect cost rates to ensure that the application of the rate is in accordance with the approved indirect cost plans, and costs used to calculate indirect costs are allowable, reasonable, and allocable under the grant requirements and regional partners are not claiming indirect costs as both direct and indirect costs. 
• Review regional partners’ indirect cost plans to substantiate the basis for their proposed indirect cost rates or confirm that an approved negotiated rate exists before approving the cooperative agreements and any continuances, as well as maintain documentation supporting that Contracts and Grants Directorate performed this review. The review should help to ensure that the costs used to calculate indirect costs are allowable, reasonable, and allocable under grant requirements. 
• Update Contracts and Grants Directorate's procedures to ensure that the Request for Advance or Reimbursement form identifies indirect costs as a cost category.
• Update Contracts and Grants Directorate's procedures to clearly indicate how regional partners should document their indirect costs on their Federal 
• Financial Reports and include a requirement for Contracts and Grants Directorate to perform periodic monitoring of the regional partners’ compliance in maintaining support for the indirect costs claimed on their Federal Financial Reports.
• Create guidance for the regional partners that demonstrates how to calculate the matching requirement in accordance with the cooperative agreements. 
• Create procedures/internal controls to ensure that personnel comply with the defined methodology during the budget approval process, including budgeting matching costs as a separate line item to facilitate review and approval of the budget from a compliance standpoint.
• Create guidance and associated procedures/internal controls to help ensure that Contracts and Grants Directorate sufficiently reviews matching costs using Federal Financial Reports to provide a basis for determining reasonableness and allowability in accordance with 2 Code of Federal Regulations Part 200 and the cooperative agreements. This should include defining and documenting the methodology used for reviewing the underlying support, such as expenditure receipts and invoices, in substantiating the reasonableness and allowability of the matching costs. 
• Assist the regional partners by communicating clear monitoring procedures for them to use in ensuring that they have sufficiently reviewed subgrantees’ matching costs to provide a basis for determining reasonableness and allowability in accordance with 2 Code of Federal Regulations Part 200 and the subgrantee awards. This should include: 3.
• Defining and documenting the methodology the regional partners should use in reviewing the underlying support, such as expenditure receipts and invoices, to help substantiate matching costs. 
• Establishing a financial reporting protocol that clearly identifies the match cost incurred.
• Identifying corrective actions the regional partners should take if they determine that subgrantees do not meet the match requirements.