Performance Audit of Incurred Costs – University of Nebraska-Lincoln

Direct UNL to strengthen its policies and procedures related to internal service center invoicing processes. Updated procedures should ensure that internal service centers only bill for services and materials based on actual usage and/or the approved internal service provider rates.

Resolve the $36,908 in questioned inappropriately allocated publication, lease, and material and supply expenses for which UNL has not agreed to reimburse NSF and direct UNL to repay or otherwise remove the sustained questioned costs from its NSF awards.

Direct UNL to strengthen its policies and procedures and internal controls for allocating expenses to sponsored projects. Updated policies, procedures, and internal controls should address how UNL will ensure:
• It charges salaries and fringe benefit expenses to NSF awards consistent with personnel action forms.
• It allocates publication expenses consistent with the benefits received by acknowledged funding sources that contributed to the published research.
• Its personnel document and justify allocation methodologies when charging expenses to NSF awards near grant expiration dates based on the benefit the NSF awards receive from the services and/or materials purchased.
• It appropriately documents and retains documentation to support the methodology it uses to allocate expenses.

Direct UNL to provide documentation supporting that it has repaid or otherwise credited the $20,058 in questioned participant support, publication, salary and fringe, and equipment expenses for which it has agreed to reimburse NSF.

Direct UNL to produce formal written guidance and provide training on how to assess and document the methodology used to allocate publication costs consistent with the benefits received by acknowledged funding sources.

Direct UNL to implement additional procedures that require Principal Investigators to regularly monitor and validate that they incurred expenses charged to NSF awards to benefit the award(s) to which they charged the expenses.

Direct UNL to implement additional procedures and controls necessary to ensure it complies with its internal policies when overseeing NSF awards. Updated controls should ensure UNL:
• Verifies that personnel perform and document a quarterly review of expenses for each NSF award each quarter.
• Monitors for approaching project verification statement deadlines and develops procedures necessary to obtain approval of all project verification statements prior to the 60-day deadline.
• Verifies that personnel obtain necessary contract approvals from the procurement department and receive, review, and maintain any required price and rate quotes prior to the final execution of a contract.
• Verifies that personnel obtain appropriate approvals for Pre-Trip Requests prior to booking any travel.
• Only approves cost transfers when documented and approved on the appropriate cost transfer form.