Open Recommendations

We recommend that BCP management more effectively communicate to agency staff clear, formalized procedures for the consistent processing and adjudication of consumer complaints referred by internal FTC offices.

We recommend that BCP management enhance the organization of CRC's knowledge base resources to ensure information is centralized and accessible to all staff.

We recommend that BCP management refine its regularly-reviewed process for identifying and capturing key CRC program input in policy or guidance.

Develop ALU engagement standards and incorporate them into acquisition policies and procedures.

Update guidance to clarify the different roles and responsibilities of the ALU, CO, CS, and COR.

We recommend that the Chief Procurement Officer develop, implement, and communicate requirements for program offices to establish written minimum roles and responsibilities for their respective procurement management functions, including but not limited to CORs, PMs, and SMEs.

Resolve the $421,495 in questioned subaward and salary expenses for which Northeastern has not agreed to reimburse NSF and direct Northeastern to repay or otherwise remove the sustained questioned costs from its NSF awards.

Direct Northeastern to provide documentation supporting that it has repaid or otherwise credited the $514,630 in questioned subaward, salary, and travel expenses for which it has agreed to reimburse NSF.

Direct Northeastern to strengthen its procedures and internal controls around invoice processing to ensure that it allocates subaward payments to the correct award.

Direct Northeastern to strengthen its internal controls and processes for obtaining NSF approval for subawards. This could include:
• Requiring Sponsored Projects Administration to verify whether the entity explicitly identified all subawards within the approved award budget or obtained written approval from the NSF Grants Officer before establishing the subaward.
• Requiring periodic training for Principal Investigators and other personnel responsible for identifying subaward agreements under NSF awards.

Direct Northeastern to strengthen its policies, procedures, and internal controls around subrecipient monitoring to ensure that subawardees comply with federal and NSF requirements when incurring expenses under NSF awards. This could include:
• Implementing additional procedures that require Northeastern to verify that subawardees submit invoices based on actual expenses incurred, rather than on the award budget.
• Developing additional resources for subawardees that provide guidance for charging allowable expenses—including salary, fringe benefit, and travel expenses—consistent with federal and NSF regulations.

Direct Northeastern to strengthen its policies, procedures, and internal controls for processing subaward invoices to ensure it only pays subawardees for the reimbursement amount requested.

Resolve the $8,080 in questioned inadequately supported salary, consultant, and material and supply expenses for which Northeastern has not agreed to reimburse NSF and direct Northeastern to repay or otherwise remove the sustained questioned costs from its NSF awards.

Direct Northeastern to provide documentation supporting that it has repaid or otherwise credited the $96,012 in questioned subaward, salary, consultant, and travel costs for which it has agreed to reimburse NSF.

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

Direct Northeastern to develop additional resources for subawardees that provide guidance regarding the types of documentation subawardees are required to create and retain to support salary, consultant, travel, and materials and supplies expenses charged to NSF awards.

Resolve the $2,812 in questioned indirect costs for which Northeastern has not agreed to reimburse NSF and direct Northeastern to repay or otherwise remove the sustained questioned costs from its NSF awards.

Direct Northeastern to provide the documentation supporting that it has repaid or otherwise credited the $6,053 in questioned indirect costs for which it has agreed to reimburse NSF.

Direct Northeastern 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 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…

Direct Northeastern to develop additional resources for subawardees that provide guidance regarding how to calculate salary expenses and allocate the expenses consistent with the benefits received by the award charged.

Direct Northeastern to strengthen its subaward monitoring procedures to ensure it verifies that its subawardees either apply the appropriate fringe benefit rates included in their negotiated agreements or document their election to use the proposed fringe benefit rates. These procedures should address how Northeastern will ensure the subawardee’s decision to use proposed fringe benefit rates will not cause the subawardee to overcharge NSF for fringe benefits in cases where fringe benefit rates decrease between the date the subaward is proposed and the date the subaward is awarded.

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

Direct Northeastern 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.

Direct Northeastern to implement internal controls to ensure that its subawardees are in compliance with their own policies prior to incurring expenses they will charge to the subaward.

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