Performance Audit of Subaward Costs – Columbia University

Direct Columbia to provide documentation supporting it has repaid or otherwise credited the $48,706 in questioned unsupported subaward and relocation expenses for which it has agreed to reimburse NSF.

Direct Columbia to implement additional procedures that require it—or its subawardees—to perform periodic reconciliations to ensure that expenses paid to its subawardees are supported by the subawardees’ financial records.

Resolve the $200,726 in questioned costs and direct Columbia to repay or otherwise remove the sustained questioned costs from its NSF awards.

Direct Columbia to strengthen its policies, procedures, and internal controls around subrecipient monitoring to ensure subawardees comply with federal and NSF requirements when incurring expenses under NSF awards. This could include developing additional resources for subawardees that provide guidance regarding the allowable charging of expenses—including salary, bonus, fringe benefit, visa, and travel expenses—consistent with federal and NSF regulations.

Direct Columbia to strengthen its procedures and internal controls around invoice processing to ensure duplicate payments are not made to subawardees.

Direct Columbia to strengthen its policies, procedures, and internal control processes for ensuring its subawardees appropriately apply either their federally negotiated indirect cost rates or the de minimis rate to NSF awards. These updated procedures could include:
• Requiring personnel responsible for approving invoices to perform a calculation in order to determine whether the indirect costs invoiced are appropriate based on the direct costs invoiced and the rate identified in the subawardee’s Negotiated Indirect Cost Rate Agreement (or the de minimis rate when the subawardee does not have a federally negotiated rate).
• Developing resources that provide guidance on appropriately applying indirect cost rates to all direct costs that should be included in the Modified Total Direct Cost base, per the subawardee’s negotiated indirect cost rate agreements and federal guidance.
• Developing resources that provide guidance on accurately classifying all costs for accounts included within the Modified Total Direct Cost base and on applying the indirect cost rate to those accounts.

Direct Columbia to establish and implement policies and procedures or internal controls for executing subaward modifications to extend the subaward period of performance prior to paying invoices under an expired subaward.

Direct Columbia to develop resources that provide its subawardees with guidance on the types of policies and procedures and financial accounting system records necessary to demonstrate compliance with federal financial management systems requirements.

Direct Columbia to update its invoice review procedures to ensure that subawardee invoices include all of the data elements required per the subaward terms and conditions.

Direct Columbia to implement additional policies or procedures to ensure that subawardees complete and submit any progress, technical, or other reports that Columbia requires per the subaward terms and conditions.

Direct Columbia to implement internal controls to ensure that Principal Investigators review and approve invoices—and document this approval—within the time limit defined in its policy.