NSF - 20-1-007 - Finding8Rec.6

Direct Yale to strengthen its administrative and management procedures surrounding the procurement of consulting services. Updated processes could include: a. Providing annual training to principal investigators and other departmental personnel responsible for approving consultant costs. This training should emphasize: i. The requirement that Yale complete purchase requisitions and, when the purchase exceeds $10,000, professional services and consulting agreements for consultants before the consultants begin providing services. ii. The type of information that should be included in the professional services and consulting agreement, including the total amount obligated for the consultant and when and how the consultant should invoice Yale for the services provided. b. Implementing a control to flag each vendor that has invoiced more than $10,000 in services to a single funding source if Yale has not executed a professional services and consulting agreement with that vendor. c. Implementing a control to flag proposed payments to independent contractors that require appropriate procurement personnel to validate a purchase requisition has been completed prior to processing the payment.