| 1.1 |
Yes |
$25,036 |
$0 |
|
|
Resolve the $25,036 in questioned travel, fringe benefit, long-term visa, participant
payment, and summer salary expenses for which Cornell has not agreed to
reimburse NSF and direct Cornell to repay or otherwise remove the sustained
questioned costs from its NSF awards. Additionally, based on Cornell’s formal response to the audit report, we alsosuggest that NSF consider whether Cornell appropriately tracked and used all
funds awarded for participant support when resolving the $809 in questioned costs for REDACTED.
|
| 1.2 |
Yes |
$39,608 |
$0 |
|
|
Direct Cornell to provide documentation supporting that it has repaid or otherwise
credited the $39,608 in questioned publication, travel, fringe benefit, and
promotional material expenses for which it has agreed to reimburse NSF
|
| 1.3 |
Yes |
$0 |
$0 |
|
|
Direct Cornell to strengthen its procedures for ensuring that it only charges
allowable costs to NSF awards. Cornell’s updated procedures should:
Require Cornell to verify that research publications acknowledge the NSF
funding source(s) to be charged before charging the publication expenses to the
NSF award(s). Address how to properly review travel, participant, and promotional material
expenses to identify unallowable costs
|
| 1.4 |
Yes |
$0 |
$0 |
|
|
Direct Cornell to update its policies to no longer permit personnel to charge
unallowable costs to NSF awards. These updated policies should not permit Cornell
to: Apply fringe benefits to stipend payments when paying stipends to Cornell
employees. Charge H-1B long-term immigration visa costs to NSF awards. Charge summer salaries at amounts that exceed the employee’s IBS at the time
the employee earned the summer salary
|
| 2.1 |
Yes |
$24,584 |
$0 |
|
|
Resolve the $24,584 in questioned inadequately supported service, participant,
health insurance, travel, and salary expenses and direct Cornell to repay or
otherwise remove the sustained questioned costs from its NSF awards
|
| 2.2 |
Yes |
$7,544 |
$0 |
|
|
Direct Cornell to provide documentation supporting that it has repaid or otherwise
credited the $7,544 in questioned service and participant expenses for which it has
agreed to reimburse NSF.
|
| 2.3 |
Yes |
$0 |
$0 |
|
|
Direct Cornell to strengthen its procedures or other internal controls for obtaining
and maintaining documentation to support costs charged to NSF awards. The
updated procedures or controls should ensure:
Vendors submit service invoices that contain sufficient detail to support that the
costs invoiced are: (i) allowable per applicable federal, NSF, and Cornell policies;
and (ii) consistent with the approved quotation or purchase order.
Principal Investigators, or other appropriate personnel, capture all participant
payment information required per the Human Research Participant Payment
policy in Cornell’s Buying Manual.
Travelers submit airfare receipts that identify the airfare class purchased.
Charges for salary paid to hourly employees are supported by employee
timesheets.
|
| 3.2 |
Yes |
$17,330 |
$0 |
|
|
Resolve the $17,330 in questioned inappropriately allocated publication expenses
for which Cornell has not agreed to reimburse NSF and direct Cornell to repay or
otherwise remove the sustained questioned costs from its NSF awards.
|
| 3.2 |
Yes |
$4,991 |
$0 |
|
|
Direct Cornell to provide documentation supporting that it has repaid or otherwise
credited the $4,991 in questioned publication, travel, and recruitment expenses for
which it has agreed to reimburse NSF
|
| 3.3 |
Yes |
$0 |
$0 |
|
|
Direct Cornell to strengthen its policies and procedures and internal controls
related to allocating expenses to sponsored projects. The updated procedures
should ensure Cornell allocates:
Publication expenses to NSF awards consistent with the benefits received by the
acknowledged funding and appropriately documents its allocation methodology.
Travel that benefits multiple projects in a manner that is consistent with agreed upon allocation methodologies.
Recruitment expenses to NSF awards in a manner that is consistent with
recruited employees’ certified effort reports
|
| 4.1 |
Yes |
$593 |
$0 |
|
|
Resolve the $593 in questioned indirect costs for which Cornell has not agreed to
reimburse NSF and direct Cornell to repay or otherwise remove the sustained
questioned costs from its NSF awards.
|
| 4.2 |
Yes |
$2,295 |
$0 |
|
|
Direct Cornell to provide documentation supporting that it has repaid or otherwise
credited the $2,295 in questioned indirect costs for which it has agreed to
reimburse NSF.
|
| 4.3 |
Yes |
$0 |
$0 |
|
|
Direct Cornell to strengthen its policies, procedures, and internal control processes
for applying its indirect cost rates to ensure it applies appropriate indirect cost
rates, including rates established in NSF budgets, to only those direct costs that it
should include in its Modified Total Direct Cost base per its applicable Negotiated
Indirect Cost Rate Agreement(s).
|
| 5.1 |
Yes |
$0 |
$0 |
|
|
Direct Cornell to implement additional procedures to ensure that it performs—and
appropriately documents its performance of—risk assessments in compliance with
federal requirements for pass-through entities and Cornell’s internal policies
|
| 5.2 |
Yes |
$0 |
$0 |
|
|
Direct Cornell to develop additional resources for subawardees that provide
guidance on how to ensure they appropriately account for and invoice expenses on a
cost-reimbursement basis consistent with subaward terms and conditions.
|
| 5.3 |
Yes |
$0 |
$0 |
|
|
Direct Cornell to implement additional policies or procedures to ensure that
subawardees complete and submit—and that Cornell reviews and maintains—any
progress, technical, or other reports that Cornell requires per the subaward terms
and conditions.
|
| 6.1 |
Yes |
$0 |
$0 |
|
|
Direct Cornell to implement additional procedures and/or internal controls, as
necessary, to ensure it complies with its internal policies when overseeing costs
charged to NSF awards. The updated controls should ensure Cornell verifies that it
and its personnel:
Use the correct procurement method and collect and approve all necessary
documentation prior to payment.
Submit expense reports and claim per diem at the lodging location rate prior to
approving travel expenses for reimbursement.
Appropriately tag all equipment charged to NSF awards for inclusion in Cornell’s
biennial physical inventory account.
|
