Open Recommendations

SFO’s approved guidance regarding Controlled Articles at SNL is up to date, aligns with current Department policies, and meets the approval of the ODFSA; and

SNL determines if an Incident of Security Concern occurred and takes appropriate action.

(U) Rec. 1.a.1: This recommendation is Controlled Unclassified Information

(U) Rec. 1.a.2: This recommendation is Controlled Unclassified Information

(U) Rec. 1.b: This recommendation is Controlled Unclassified Information

(U) Rec. 1.c: This recommendation is Controlled Unclassified Information

(U) Rec. 1.d: This recommendation is Controlled Unclassified Information

We recommend that the FWS require the Department to update guidance to include justifications for determining whether WSFR funds pass through as subawards or contracts.

We recommend that the FWS require the Department to analyze and provide justification regarding the allowability of investment of license revenue by the New York State Office of the State Comptroller.

We recommend that the FWS require the Department to resolve any potential diversion of license revenue.

We recommend that the FWS require the Department to ensure staff are trained on how to make subaward determinations using the newly developed guidance and provide evidence of training.

Resolve the $72,578 in questioned indirect costs for which MSU has not agreed to reimburse NSF and direct MSU to repay or otherwise remove the sustained questioned costs from its NSF awards.

Direct MSU to provide documentation supporting that it has repaid or otherwise credited the $14,303 in questioned airfare, participant support costs, and Graduate Research Fellowship Program (GRFP) expenses for which it has agreed to reimburse NSF.

Direct MSU to strengthen its policies and procedures related to the capitalization of constructed equipment. Updated policies should require MSU to capitalize any constructed items that meet its definition of equipment and exclude the cost of these items from its modified total direct cost base.

Direct MSU to develop formal policies and procedures for reviewing subawardee invoices to verify that the subawardee is appropriately applying indirect costs using the rate(s) included in the subawardee’s approved Negotiated Indirect Cost Rate Agreement(s) before approving the invoice for payment.

Direct MSU to strengthen its procedures for booking and approving travel expenses. Updated procedures could include: • Requiring travelers to perform a cost comparison when booking flights that include any unallowable upgrades so the travelers are able to document the difference in cost between the standard economy airfare and the airfare including the upgrades. • Requiring personnel approving expense reports to verify that travelers actually performed the scheduled travel and that the travelers did not claim expenses for any unused, credited, or refunded expenses prior to approving expense reports.

Direct MSU to implement additional procedures that require routine reviews of all expenses charged to NSF awards as participant support costs to verify that MSU incurred the costs to support NSF award participants.

Direct MSU to strengthen its procedures surrounding GRFP stipend payments. Updated procedures should ensure that MSU pays GRFP stipends using the stipend rate identified in the relevant NSF GRFP solicitation.

Resolve the $9,702 in questioned inadequately supported lodging expenses for which MSU has not agreed to reimburse NSF and direct MSU to repay or otherwise remove the sustained questioned costs from its NSF awards.

Direct MSU to provide documentation supporting that it has repaid or otherwise credited the $12,313 in questioned airfare and internal service expenses for which it has agreed to reimburse NSF.

Direct MSU to strengthen its policies and procedures surrounding the review of expense reports to require reviewers to verify that travelers have supported all costs claimed as allowable per federal and NSF regulations before charging the costs to NSF awards. Updated policies should ensure that travelers: • Provide itemized receipts when booking travel through travel agencies. • Support all lodging costs claimed with documentation that includes an agreed-upon rate (such as a hotel receipt or a formal lease agreement).

Direct MSU to develop formal policies and procedures for establishing internal service provider rate agreements and for verifying that MSU has appropriately reviewed and approved the rate agreements before charging those rates to NSF awards.

Direct MSU to provide documentation supporting that it has repaid or otherwise credited the $6,439 in questioned publication and tuition expenses for which it has agreed to reimburse NSF.

Direct MSU to strengthen its policies and procedures and internal controls for allocating expenses to sponsored projects. Updated procedures could require: • Individuals incurring publication expenses to document and justify the allocation methodology used when publishing research that identifies multiple sponsoring funding sources. • MSU to remove all costs charged to NSF awards for tuition that relates to time period(s) after the award’s period of performance has expired as part of the award close-out activities and verify that it allocates tuition consistent with student effort.

Direct MSU to provide documentation supporting that it has repaid or otherwise credited the $3,906 in questioned Award Cash Management $ervice drawdowns for which it has agreed to reimburse NSF.