Open Recommendations

We recommend the Secretary, in coordination with DHS components and FPS, establish and implement a plan, policy, and process toimprove preparedness for multi-component response to future incidents of civil disturbance at Federal facilities, including:A. a process for designating DHS component personnel under 40 U.S.C. §1315 and verification of required legal training completion;B. equipment and training needs and requirements; andC. consistent tactics and operational policies.

We recommend that the IA coordinate with Pine Hill School to ensure that the general facility deficiencies noted in this report are either addressed or included as part of the consolidation and renovation of the school facilities (Phase II).

We recommend that the IA coordinate with Pine Hill School to complete the planned consolidation and renovation (Phase II).

We recommend that the IA coordinate with Pine Hill School to complete the gymnasium replacement project (Phase III).

Direct Clemson to strengthen its monitoring procedures and internal control processes for applying indirect costs to Federal awards. Updated procedures could include: a. Requiring that personnel assess whether Clemson should capitalize ongoing and future construction projects. Specifically, Clemson should consider Federal regulation specific to the capitalization of construction related to additions to, improvements to, alterations of, or reconfigurations of Clemson buildings when Clemson uses Federal funding to finance construction. b. Requiring that personnel manually review capitalized charges made to an award to ensure that Clemson has included all applicable costs in the capitalized amount. Specifically, Clemson should consider whether capitalized…

Direct Clemson to provide documentation supporting that it has repaid or otherwise credited the $36,847 of questioned equipment, travel, other direct costs, and publication costs for which it has agreed to reimburse NSF.

Direct Clemson to strengthen its administrative and management controls and processes for allocating expenses to sponsored projects. Updated processes could include: a. Implementing additional procedures requiring the Office of Grants and Contracts Administration to review and approve all non-salary expenses charged to NSF awards within 90 days of the award’s expiration date. b. Requiring Principal Investigators or other designated staff to both document and justify the allocation methodologies they used when charging expenses to sponsored projects. c. Establishing a procedure to justify allocating travel expenses to specific NSF awards by confirming travel charged to an award contributes to the grant…

Direct Clemson to encourage Principal Investigators to identify and report all awardrelated travel in their annual reports to NSF.

Direct Clemson to implement a process to ensure that personnel review the reasonableness of all employee, non-employee, and participant travel days and charges at the time of reimbursement.

Direct Clemson’s Office of Grants and Contracts Administration to provide training on how to assess the methodology for allocating publication costs across each sponsored award acknowledged in the publication and document the justification for this methodology.

Direct Clemson to periodically assess the fee structure and period allotted for access to the computer cluster node infrastructure. Updated procedures could include: a. Requiring the Office of Grants and Contracts Administration to assess whether projects require access to the computer infrastructure. b. Establishing the time and fee structure as a specialized service center to ensure appropriate cost objective control.

Direct Clemson to strengthen its administrative and management procedures and internal controls for allocating expenses to sponsored projects. Updated procedures could include: a. Requiring the Office of Grants and Contracts Administration to provide training on allocation methodology for costs incurred on sponsored projects. b. Requiring Principal Investigators or other designated staff to review and justify the allocation methodologies they used when charging computer cluster node costs to sponsored projects.

Direct Clemson to strengthen its policies and procedures related to 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 expenses charged to sponsored programs. Updated procedures could include: a. Conducting annual training for individuals responsible for reviewing and approving consultant expenses, including training regarding what documentation Clemson must maintain to support consultant rates charged. b. Establishing clear guidance regarding what documentation Clemson must maintain in cases in which an individual books their own airfare. c. Establishing clear guidance as to who is required to…

Direct Clemson to strengthen its policies and procedures related to 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 expenses charged to sponsored programs.

Direct Clemson to strengthen its administrative and management processes and procedures surrounding the approval of travel expense reports. Updated procedures could include: a. Establishing clear guidance regarding the allowability of registration fees when individuals are no longer able to attend the event. b. Developing a procedure to evaluate travel that occurs near the end of an award and remove any travel costs associated with trips that occur after the award expires. c. Conducting annual training for individuals responsible for reviewing and approving expense reports within each department, to define what expenses are allowable on a sponsored program. d. Establishing clear…

Direct Clemson to establish clear guidance regarding the allowability of participant support funding for employee travel.

Direct Clemson to establish procedures to ensure that its salary payments do not exceed the employee’s Institutional Base Salary.

Direct Clemson to update its current proposal submission and award set-up practices to require that, when setting up accounts established for supplemental funding for NSF awards, personnel ensure that the accounts apply indirect costs as directed by the supplemental funding letter.

Direct Clemson to ensure that it has performed risk evaluations for all subawards issued prior to June 2018 and that these risk evaluations remain active, to validate the agreements in accordance with Federal regulations.

Direct Clemson to update its current pre-award procedures and internal controls for reviewing NSF proposal budgets to ensure that all costs included in the participant support cost budget comply with NSF terms and conditions.

Direct Clemson to update its current procedures and internal controls to ensure that Principal Investigators submit final reports to NSF in accordance with NSF’s terms and conditions. Updated procedures should require Clemson to verify the submission of the final report with both the Principal Investigators and NSF during project close-out or when the Principal Investigator is leaving Clemson.

Direct Clemson to strengthen its administrative and management procedures for equipment expenditures to ensure that the Office of Grants and Contracts Administration approves all equipment purchased with non-sponsored funds and subsequently transferred to sponsored funds.

Direct Clemson to strengthen its administrative and management procedures to confirm it has completed the subrecipient documentation package before approving non-budgeted subawards.

Direct Clemson to strengthen its administrative and management procedures and internal controls related to the effort certification process. Updated procedures could include requiring Office of Grants and Contracts Administration personnel to follow up with any personnel that do not certify their effort reports within 30 days.

Direct Clemson to strengthen its administrative and management processes surrounding document retention for purchases on sponsored awards.