Performance Audit of Incurred Costs – Cal Poly Corporation

Direct Cal Poly to implement additional administrative and management procedures surrounding the payment of intra-Institution of Higher Education consulting services. Updated procedures should require that Cal Poly: • Request and receive approval from NSF before charging NSF awards for intra-Institution of Higher Education consulting payments made to Cal Poly employees. • Document the methodology used to calculate the amount of any intraInstitution of Higher Education consulting payments made to Cal Poly employees.

Direct Cal Poly to strengthen its administrative and management controls and processes for supporting the allocation of expenses to sponsored projects. Updated processes could include: • Implementing a standard documentation and retention process to support the allocation of publication costs that benefit multiple awards. • Requiring Principal Investigators or other designated staff to both document and justify the allocation methodologies used when charging expenses to sponsored projects near the grant expiration date. • Performing reconciliations at the end of each summer program to verify that the costs charged to sponsored projects were appropriate based on the number of program participants.

Direct Cal Poly 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 travel expenses charged to sponsored programs. Updated procedures could include: • Requiring travelers to document the business purpose of each day of a planned trip before charging travel costs to NSF awards. • Implementing additional reviews for all airfare purchases, including requiring the reviewer to verify that the traveler purchased an economyclass ticket before charging the expense to an NSF award. • Verifying that subawardees claiming travel costs on federal awards provide sufficient documentation to support the allowability of claimed expenses.

Direct Cal Poly to (i) strengthen its administrative and management procedures to ensure travelers submit their travel expense reports within 10 days of returning from their trip, and/or (ii) update its policies and procedures to reflect its current expense reimbursement policies.