Trustees of Tufts College d/b/a Tufts University

2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings

2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings

2023-002 – Equipment Management Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with equipment Award Name: Various - All R&D Cluster awards with equipment Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with equipment Assistance Listing Number: Various – All R&D Cluster awards with equipment Condition The University has a process in place whereby a third-party is engaged to scan all equipment (federal and nonfederal) across their 3 campuses every two years. The third-party does not have a detailed listing when performing their inventory and thus the University must reconcile what was located by the thirdparty to their detailed equipment listing and understand why certain items were not located. If not located, follow-up is performed on an asset-by-asset basis by the University requesting the custodian of the asset confirm the equipment is on-hand. While we University provided evidence of the third-party inventory being performed, including a related manual reconciliation process, we were unable to obtain an aggregated reconciliation between the University equipment records and the third-party inventory results that included all follow-up information as the process is currently manual and disaggregated. Additionally, when scanning through the detailed listing of federal assets, certain equipment was noted to have an inventory date outside of the past 2 years. Criteria 2 CFR 200.313(d) requires that a physical inventory of equipment acquired in whole or in part under a Federal award must be taken and the results reconciled with the property records at least once every two years. Cause The University’s process for reviewing third-party equipment inventory results and conducting follow-up is manual, which can cause delays. Additionally, an aggregated reconciliation is not maintained, which can result in an incomplete or inaccurate inventory listing. Effect The lack of a formal reconciliation may result in incomplete equipment inventory records and/or certain assets not being physically inspected within the required 2-year period. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University update their policies and procedures to require an aggregated reconciliation be maintained between third-party equipment inventory results and University equipment records. Additionally, the University should develop a more automated approach to resolving discrepancies between the third-party equipment inventory results and the federally funded equipment listing, rather than utilizing a manual process, which can cause delays. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings

2022-001 Indirect cost rate incorrectly applied to HEERF lost revenue Cluster: Not appliable Grantor: Department of Education Award Name: COVID-19 - Higher Education Emergency Relief Fund (?HEERF?) ? Institutional Portion Award Year: FY2021 Assistance Listing Number: 84.425F Condition During the year ended June 30, 2022, the University expended $6,026,364 in HEERF III Institutional Portion funds and of that amount, $1,088,066 pertained to amounts claimed as indirect costs. Through testing of indirect costs, it was noted that the University appropriately made adjustments to their direct cost base to remove direct expenses associated with rental activities, consistent with the Uniform Guidance and the definition of Modified Total Direct Costs. However, lost revenue claimed was included in the direct cost base which resulted in indirect costs being overstated by $759,410. Following this, upon further review the University identified other costs that are allowable to swap out the identified unallowable costs, amended their Q1 2022 and Q2 2022 reports and reposted these reports to their website. Criteria Department of Education HEERF guidance notes that indirect costs may be charged only to Institutional Portion awards, both new and supplemental, and generally, this indirect cost rate will be the on-campus rate specified in an institution?s negotiated indirect cost rate agreement. Specifically, the 2022 OMB Compliance Supplement notes that an institution may not apply an indirect cost rate to its estimated amount of lost revenue. Cause The University was not aware indirect costs could not be charged to lost revenue, due to this information not being explicitly stated in various Department of Education HEERF published guidance and HEERF FAQs. Effect The University claimed too much under HEERF III for indirect costs versus identifying other allowable qualifying activities under HEERF III and had to amend their previous quarterly report submissions. Questioned Costs Indirect costs claimed were overstated by $759,410. However, those costs were ultimately replaced with other allowable expenses. Recommendation We recommend the University continue to strengthen their control environment around the review and approval of costs to be charged to federal awards, particularly when the awards are not directly managed through the sponsored research office. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.

2021-001 HEERF Quarterly Institutional Reports ? Misclassification of certain expenses Cluster: Not appliable Grantor: Department of Education Award Name: COVID-19 - Higher Education Emergency Relief Fund (?HEERF?) ? Institutional Portion Award Year: FY2021 Assistance Listing Number: 84.425F Criteria The terms and conditions of the HEERF I, II and III institutional portion certification and agreements indicate that recipients must promptly and timely provide a detailed accounting of the use of funds provided by the awards in such manner and frequency as the Department of Education Secretary may require. Additional guidance specific to these reports, requires quarterly reports to be posted to an institution?s website in a format prescribed by the Department of Education, which includes spending by funding category. Condition Through review of 25 direct costs selected for testing for the institutional portion, we tested the classification of these costs on the quarterly institutional reports posted by the University. We noted no issues specific to allowability, however, 5 expense selections were classified on the December 2020 quarterly report in a manner inconsistent with the nature of the expense. Specifically, we noted the following: ?$122,563 of costs categorized as "providing or subsidizing the costs of high-speed internet tostudents or faculty to transition to an online environment", which would have been moreappropriately classified as "campus safety and operations" ($106,313) and "covering the cost of providing additional technology to students such as laptops or tablets, or covering the added cost of technology fees" ($16,250). ?$3,432 of costs were classified as ?covering the cost of providing additional technology hardware to students, such as laptops or tablets, or covering the added cost of technology fees? which would have been more appropriately classified as ?purchasing, leasing or renting additional equipment and supplies??. Cause The detail comprising the quarterly reports was aggregated based on the nature of the expense at the invoice level, however, the underlying detail of the invoice was not reviewed when compiling the report, rather the vendor name and/or brief description of the transaction was relied on. Effect While the quarterly reports were completed timely, the totals were accurate and the expenses were allowable, the individual funding categories were not accurate for certain of the expenses, thus not providing complete and accurate information to readers. Questioned Costs None noted. Recommendation We recommend the University implement a control whereby the funding category on the quarterly institutional reports is reviewed concurrently with making the allowability determination upon review of the invoice level detail. The Director of Post-Award Research Administration and/or the University Controller should review the reasonableness of expense classification on a sample basis. Ultimately, the quarterly institutional reports should continue to be reviewed and approved by the University Controller. Management?s Views and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary schedule of status of prior audit findings.

2020-001 Subrecipient Monitoring ? Evidence of review of terms and conditions within certain subaward agreements Cluster: Research & Development Grantor: National Institutes of Health; Agency For International Development; Department of Army Research and Material Command; Department Of State, Bureau Of Educational And Cultural Affairs Award Name: National Center for Advancing Translational Sciences; USAID Foreign Assistance for Programs Overseas; Military Medical Research and Development; Aging Research; Global Threat Reduction Award Year: FY2020 CFDA Numbers: 93.350; 98.001; 12.420; 93.866; 19.033 Criteria 2 CFR ? 200.332 includes information that is required to be identified to a subrecipient in their subaward, including any additional requirements that the pass-through entity imposes on the subrecipient and any additional terms and conditions that are deemed appropriate. As part of the University?s policies and procedures a Risk Assessment Questionnaire is completed to evidence a review of the financial and performance risks associated with each subrecipient award, which includes the review of the subaward terms and conditions. If it is determined that the University?s standard subaward terms should be modified, the justification for the modification must be reviewed by an Associate Director or Director and evidence of this review maintained in the Risk Assessment Questionnaire. Additionally, subrecipients determined through the Risk Assessment Questionnaire to be medium or high risk, require a review to determine if additional terms should be added to the subaward agreement. Documentation is required to be maintained evidencing whether or not additional terms were added and the Pre-Award Director or Associate Director are required to sign-off on this determination. Condition Through our testing of subrecipient monitoring for 25 subrecipients, which included the review of the University?s Risk Assessment Questionnaires, we noted the following specific to the documentation of review of certain terms and conditions within the subawards: ? Two foreign subrecipients had amendments to the original terms and conditions within their subaward agreements where justification and review by the Associate Director or Director pertaining to the amendments were not evidenced per the University?s policy. ? Three subrecipients in the sample were deemed medium or high risk, triggering a potential need for adding additional terms to the formal agreements. Additional terms were not added, however, the Risk Assessment Questionnaire did not include the rationale for not adding or modifying the standard terms per the University?s policy, including the Pre-Award Director or Associate Director?s approval. Cause The preparer of the risk assessment in error did not properly document the amendments or rationale in the risk assessment to trigger a review of the Director or Associate Director, as was required per University policies and procedures. Effect Lack of review of subaward agreements could lead to incomplete agreements that could impact the level of subrecipient monitoring completed by the University. Questioned Costs None noted. Recommendation We recommend the pre-award group implement a control whereby prior to sign-off on the final Risk Assessment Questionnaire, the completeness of all reviews throughout the questionnaire are validated. This should include reviewing the subaward agreements to ensure in situations where additional terms and conditions were added review was evidenced and for medium or high risk rated subawards that the documentation evidences review regardless of whether additional terms were added. We also recommend training be provided with pre-award staff to ensure they understand the workflow requirements for subaward agreements prior to execution. Management?s Views and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary schedule of status of prior audit findings.

Criteria Certain health professions students may borrow amounts up to $26,667 under the direct unsubsidized loan program in addition to the annual unsubsidized loan limit of $20,500. This applies to graduate and professional students when enrolled in an eligible program, which includes the University?s School of Dental Medicine International Student (DIS) Program. Annual additional unsubsidized loans awarded must be prorated for an academic year less than 12 months. The second academic year of the DIS Program is 11 months long and as a result, the prorated annual loan limit for eligible second-year DIS students is $44,944. (34 CFR 685.203(c); Federal Student Aid Handbook Volume 3 ? Calculating Awards & Packaging, 2018-19). Condition Through our eligibility testing of 25 students at the School of Dental Medicine, we noted 4 instances where students were awarded unsubsidized direct loans totaling $47,167, which exceeded the prorated annual limit of $44,944 for a program covering 11 months by $2,223. Cause The School of Dental Medicine has a control whereby all financial aid packaging formulas within their student financial aid system are reviewed by the Director of Enrollment Services prior to commencing the award packaging process. However, the 11-month second-year DIS program was incorrectly bundled with the 12-month Doctor of Dentistry program and this error was not identified during the review process. As such, the unsubsidized direct loan proration criterion was omitted in the second year DIS students? award calculations. Effect The system packaging error resulted in the direct unsubsidized loan proration criteria for second year DIS students being omitted and excess loans being awarded to second-year DIS students and drawn down by the University from the Department of Education. Questioned Costs $8,892 Recommendation We recommend that the School of Dental Medicine complete more robust testing of the packaging formulas to ensure all cohorts are calculated appropriately within the student financial aid system prior to commencing the packaging process and perform periodic subsequent checks throughout the payment periods to ensure that direct loan annual limits are calculating appropriately. The School of Dental Medicine should also review all students that were impacted by this issue and determine what amount in the aggregate should be returned to the Department of Education. Management?s Views and Corrective Action Plan Management?s views and corrective action plan are included at the end of this report after the summary schedule of status of prior audit findings.

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