Open Recommendations

Resolve the $169,950 in questioned consulting and subaward costs and direct OSU to repay or otherwise remove the sustained questioned costs from its NSF awards.

Direct OSU to establish a policy to ensure that OSU employees are not paid as both employees and independent contractors. We noted that OSU updated OSU Policy 402- 006, Personal Services Contracts, in response to our audit; however, we determined that OSU’s revision does not sufficiently address cases such as the one described in this finding.

Direct OSU to strengthen its administrative and management procedures over awarding subawards to ensure that: a. Personnel who receive, or work for an organization that receives, a subaward contract are not involved in selecting or awarding it, or in performing administrative services for it. b. Cost-reimbursable subaward agreements do not include billing schedules. c. Subawardees submit budgets with accurate information on each employee’s salary, if the subawardees will submit invoices on a cost-reimbursable basis and OSU will charge these costs to a Federal award.

Resolve the $78,153 in questioned equipment, consultant, salary, travel, participant support, and leave payout costs and direct OSU to repay or otherwise remove the sustained questioned costs from its NSF awards.

Direct OSU to strengthen its administrative and management procedures for obtaining NSF’s approval before making changes to an award’s scope. Procedures could include verifying that the sponsor approved the change in scope before allowing PIs to charge awards for expenses that are inconsistent with the scope of the original award.

Direct OSU to strengthen its administrative and management procedures for allocating salary and associated accumulated leave expenses to sponsored projects. Procedures could include: a. Updating award close-out procedures to require personnel to review all payroll charged to an award after the award’s POP has ended, to verify that OSU incurred the expenses during the award’s POP. b. Updating its procedures for the approval of vacation leave payout to ensure that departments/units obtain OSRAA’s approval before charging payouts to sponsored awards.

Direct OSU to strengthen its administrative and management procedures for allocating travel expenses to sponsored projects. Procedures could include: a. Performing periodic reviews of expense reports that OSU personnel submit under NSF awards to ensure that all costs charged comply with Federal and NSF regulations and OSU policies and procedures. b. Conducting annual training for individuals responsible for reviewing and approving expense reports.

Direct OSU to strengthen its administrative and management procedures for allocating equipment or general-purpose equipment expenses to sponsored projects. Procedures could include requiring that PIs request specific approval from NSF before charging general-purpose equipment to NSF awards.

Direct OSU to strengthen its administrative and management procedures over the use of PSC funding under NSF awards. Processes could include requiring an annual review of all costs charged to PSC accounts to verify that the PI incurred the expenses for the purpose(s) outlined in the award budget.

Resolve the $65,153 in questioned indirect costs and direct OSU to repay or otherwise remove the sustained questioned costs from its NSF awards.

Direct OSU to strengthen its administrative and management procedures for applying indirect costs to Federal awards. Processes could include: a. Requiring that personnel manually review materials/supplies and software purchases to evaluate whether OSU should account for the items as equipment. Specifically, OSU should consider whether the items purchased either cost more than $5,000 or are necessary for the use of an asset that would have a total value of more than $5,000. b. Implementing an annual review process for travel costs charged to awards that include funding for PSCs to ensure that OSU is appropriately segregating PSCs in accounts that…

Resolve the $31,319 in questioned supplies, equipment, and travel costs and direct OSU to repay or otherwise remove the sustained questioned costs from its NSF awards.

Direct OSU to strengthen its administrative and management procedures for purchasing equipment and materials/supplies at the end of a project’s POP. Processes could include requiring OSRAA to review all equipment and materials/supplies purchased within the final 90 days of a sponsored award’s POP to evaluate whether the costs charged appear to be reasonable, allocable to, and allowable under the award charged.

Direct OSU to strengthen its administrative and management procedures for travel taken within the final 90 days of an award’s POP. Processes could include updating travel policies and procedures to require that OSRAA pre-approve all travel taken on sponsored projects within the final 90 days of an award’s POP.

Resolve the $10,574 in questioned unallocable costs and direct OSU to repay or otherwise remove the sustained questioned costs from its NSF awards.

Direct OSU to strengthen its administrative and management controls and processes for allocating expenses to sponsored projects. Processes could include requiring PIs or other designated staff to document the allocation methodology used to charge expenses to sponsored projects, and to provide a detailed justification for using that methodology.

Direct OSU to encourage PIs to identify all award participants and report all award-related travel in the annual reports submitted to NSF.

Resolve the $8,820 in questioned honorarium costs and direct OSU to repay or otherwise remove the sustained questioned costs from the NSF award.

Direct OSU to strengthen its administrative and management procedures for honorarium payments. Procedures could include addressing specifically how to document honorarium payments.

Resolve the $5,563 in questioned lodging and M&IE costs and direct OSU to repay or otherwise remove the sustained questioned costs from the NSF award.

Direct OSU to strengthen its administrative and management procedures for reimbursing M&IE expenses. Processes could include: a. Requiring employees to use the same meal reimbursement method throughout an entire trip, rather than determining the method on a meal-by-meal basis. b. Performing periodic reviews of M&IE per diem reimbursements to validate that the rates claimed correspond to the rates applicable to the traveler’s location.

Direct OSU to strengthen its administrative and management procedures for reimbursing lodging expenses claimed at a rate that exceeds the allowable per diem rate. Processes could include: a. Requiring travelers on sponsored projects to request approval from OSRAA when they anticipate incurring lodging expenses that exceed the allowable per diem rate. b. When applicable, maintaining documentation to support that the rates offered by the conference lodging provider were not available at the time the traveler booked the lodging.

Direct OSU to strengthen its administrative and management procedures for travel, procurement, PSCs, effort certifications, cost transfers, fellowship appointments, and currency conversions on sponsored awards. Procedures could include: a. Requiring periodic training for PIs and other personnel responsible for making travel arrangements, purchasing services, charging PSCs, certifying effort reports, processing cost transfers, and appointing fellows on sponsored awards. b. Implementing controls that would prevent OSU personnel from traveling or appointing fellows on sponsored projects without first obtaining OSRAA’s approval. c. Requiring award participants to provide cost comparisons for all travel requests that include personal or train travel before OSU approves…

Direct OSU to strengthen its administrative and management procedures for establishing indirect cost rates for Federal awards to ensure that it applies costs at the rates in effect as of the effective date of the award.

We recommend that the Ohio Department of Medicaid implement system prompts in Ohio Benefits that encourage users to verify the beneficiary’s date of birth or gender before making changes in the system