Yale University

2025-001 –Procurement, Suspension and Debarment Cluster / Program: Research & Development (R&D) / ALN 19.UO9, 19.U10: The MITRE Corporation – U.S. Department of State Grantor: - Defense Advanced Research Projects Agency (DARPA) / DoD, National Science Foundation (NSF) / U.S. Department of State Award Name: EE Tang MPI PennST DARPA Monolithic GaN, Social Networks and Migration in Nepal / Conflict Observatory – Sudan, Conflict Observatory – Ukraine Award Number: AWD0011529, AWD0007921 / AWD0011946, AWD0010905 Award Year: FY2025 Assistance Listing Numbers: 12.910, 47.075 / 19.U09, 19.U10 Assistance Listing Titles: Research and Technology Development, Social, Behavioral, and Economic Sciences / U.S Department of State Pass-Through Entities: N/A / Pennsylvania State University Criteria Per 2 CFR 200.214, when entering into a covered transaction with an entity, the auditee must have established procedures to verify that the entity is not suspended, debarred or otherwise excluded from participating in the transaction. Condition We selected a sample of 25 transactions within the R&D cluster and 5 transactions within ALN 19.U09, 19.U10 and noted two selections within R&D cluster and one selection within ALN 19.U09, 19.U10 where debarment checks were not performed prior to entering into the transaction. Cause Due to the manual nature of the debarment checks, there was an oversight and the vendors were not screened at the time of set up due to human error. Effect New vendors are not consistently checked for suspension and debarment prior to the University entering into a transaction with the vendors as required by the regulation stated above. Questioned Costs None noted. Repeat Finding in the Prior Year No Recommendation PwC recommends additional training for employees responsible for suspension and debarment checks to ensure established procedures are followed when entering into a covered transaction with an entity. Additionally, we recommend considering an automated process where when a new vendor is entered into the system, a debarment check is automatically initiated.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the Title IV, HEA programs (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Finding No. 2022-001 ? ReportingAward InformationGrantor: Department of EducationAward Name: HEERF II Institutional GrantsAward Year: 4/19/2021 ? 4/18/2022Federal Assistance Listing Number: 84.425F, HEERF II Institutional GrantsPass Through Number: Not applicableCriteriaQuarterly Public Reporting for (a)(l) Institutional Portion, (a)(2), and (a)(3) funds (Assistance Listings84.425F, 84.425J, 84.425K, 84.425L, 84.425M, 84.425N, 84.425S, as applicable)The CARES, CRRSAA, and ARP institutional quarterly portion reporting requirements involve publiclyposting completed forms on the institution's website.The forms must be conspicuously posted on the institution's primary website on the same page thereports of the IHE's activities as to the emergency financial aid grants to students (Student Aid Portion)are posted.A new, separate form must be posted covering aggregate amounts spent for HEERF I, HEERF II, andHEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30),concluding after an institution has expended and liquidated all (a)(l) Institutional Portion, (a)(2), and (a)(3)funds and checks the "final report" box. IHEs must post this quarterly report form no later than 10 daysafter the end of each calendar quarter (October 10, January 10, April 10, July 10) apart from the firstreport, which was due October 30, 2020, and the report covering the first quarter of 2021, which is dueJuly 10, 2021.ConditionYale expended both institutional and student funds received under the Higher Education EmergencyRelief Fund in the form of student grants. Yale reported its institutional expenditures in conjunction withits student expenditures. However, the regulations require a separate report for student and institutionalexpenditures. As a result of the combined reporting, Yale did not publicly post the institutional quarterlypublic report for the quarter ending June 30, 2021 that was due no later than July 10, 2021.Questioned CostsNo questioned costs as the finding is related to a reporting matter.CauseIt was an oversight on management?s behalf regarding the required institutional filing. Managementbelieved that the University complied with its reporting obligation by reporting all of the student grantexpenditures within the required student reports. The University should have publicly posted therequired institutional report and noted that all funds were given to students through grants. EffectThe University did not comply with the requirement to submit the institutional report within 10 days afterJune 30, 2021. Management has subsequently filed the required institutional report.RecommendationWe recommend the University continue to monitor the required reporting requirements related to COVIDrelated funding. As periodic updates are made to the reporting requirements, management shouldensure processes are enhanced to allow for complete and timely filing of all required reports.

Finding No. 2021-001 ? Allowable Costs/Cost PrinciplesAward InformationGrantor: National Heart, Lung and Blood Institute (NHLBI)/NIH/DHHS, Army Medical ResearchAcquisition Activity (AMRAA)/Army/DoD, Connecticut Dept. of Public Health (DPH)Award Name: Insights into the Molecular and Cellular Mechanisms governing EndothelialFunction, The Collaboration Linking Opioid Use Disorder and Sleep ("CLOUDS") Study,Behavior Therapy for Irritability & Agression in Adolescents with Autism, EmergingInfections Program (EIP)/COVID19Award Year: 1/1/21-12/31/21(AWD0000824), 9/1/20-8/31/21 (AWD0003836), 8/1/20-7/31/21(AWD0005208), 10/19/20-10/18/21 (AWD0005465)Federal Assistance Listing Number: 93.837, Cardiovascular Diseases Research; 93.233,National Center on Sleep Disorders Research; 12.420, Military Medical Research andDevelopment; 93.323, Epidemiology and Laboratory Capacity for Infectious Diseases(ELC)Pass Through Number: SUBK00014315 (AWD0005465)Criteria1. Prior to December, 2020, Yale?s policy 1104 on approval authority read as follows ?For sponsoredawards, Initiators/Requestors other than the Principal Investigator must be authorized by thePrincipal Investigator to initiate transactions on the account. The authorization must bedocumented in the award file.?2. Yale?s policy 3215 on expense management reads ?Individuals are expected to prepare andsubmit expense reports, with supporting documentation, within thirty (30) days from the date theexpense is incurred.?Condition1. We selected 31 accounts payable expenditure transactions totaling $304,987 for direct costtesting within the R&D cluster and noted one selection totaling $2,715 that was initiated by anindividual that was not the PI and the individual had not been delegated approval authority withinthe respective limits of the charges under the respective awards. There were additionally threecharges that were not submitted timely in accordance with Yale policy. These expenditures werein compliance in terms of allowability.2. We selected 10 accounts payable expenditure transactions totaling $85,938 for direct cost testingwithin the award, Connecticut Dept. of Public Health (DPH) Epidemiology and LaboratoryCapacity for Infectious Diseases (ELC), and noted one selection totaling $429 that was initiatedby an individual that was not the PI and the individual had not been delegated approval authoritywithin the respective limits of the charges under the respective awards. There was additionallyone charge that was not submitted timely in accordance with Yale policy. These expenditureswere in compliance in terms of allowability.Questioned CostsNot applicable as the expenditures were allowable.CauseR&D ClusterAWD0000824There was one expenditure where the individual that initiated the charge had delegation of initiatorauthority on the award, however the delegation period was extended and the PI did not sign the extensionform.AWD0003836Two expenditures were expense reports that were not submitted timely in accordance with Yale policy.Due to employees working from home due to the COVID-19 pandemic there was a delay in submitting theexpense report.AWD0005208One expenditure was an expense report that was not submitted timely in accordance with Yale policy.Due to employees working from home due to the COVID-19 pandemic there was a delay in submitting theexpense report.Connecticut Dept. of Public Health (DPH) Epidemiology and Laboratory Capacity for InfectiousDiseases (ELC)AWD0005465There was one expenditure where the individual that initiated the charge had delegation of initiatorauthority on the award, however the delegation of initiator was documented after the purchase occurred.There was additionally one expenditure that was an expense report that was not submitted timely inaccordance with Yale policy. Due to employees working from home due to the COVID-19 pandemic therewas a delay in submitting the expense report.EffectInconsistencies in the application of controls surrounding direct costs could result in inappropriatecharges being made to the award, causing non-compliance with the federal awarding agency regulationsand potential reduction in funding in future years.RecommendationWe recommend that the University provide additional training to staff on the appropriate approvalauthority and documentation that is required to be on file prior to allowing them to initiate a charge tofederal awards. In addition, we recommend that the University provide training on timeliness ofsubmission of expense reports.Management?s Views and Corrective Action PlanManagement's views and corrective action plan is included in Section V.

Finding No. 2020-001 ? Procurement Award Information Cluster: Research & Development (R&D) Grantor: National Institute on Alcohol Abuse and Alcoholism (NIAAA)/NIH/DHHS National Institute on Alcohol Abuse and Alcoholism (NIAAA)/NIH/DHHS; National Science Foundation (NSF) Award Name: 2/6 COMpAAS U01: Observation Study; Enhancing biomedical training and diversity through a Hispanic science network; Downsizing Democracy: Why Ordinary People Acquiesce to Authoritarianism Award Year and Award Number: September 1, 2016 ? August 31, 2020 (AWDA10923); August 15, 2019 ? July 31, 2022 (AWD0003614) CFDA Number: 93.273, Alcohol Research Programs; 47.075, Social, Behavioral, and Economic Sciences Criteria 2 CFR 200.320 states that if the small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. The University defines their micro-purchase threshold as $10,000 and the Simplified Acquisition Threshold as $150,000. Purchases that fall between the micro-purchase threshold and the Simplified Acquisition threshold are considered to be small purchases. Condition We selected 25 transactions for procurement testing within the R&D cluster and noted two selections that were greater than the University?s small purchase threshold where no price, rate quotations or sole source documentation was obtained. Please refer below for details of each award. AWDA10923- $15,789 - Annual repository maintenance fee paid to a vendor for biomarker storage. AWD0003614- $18,435 - This amount relates to consulting services. Questioned Costs None noted as these costs were allowable under the awards. Cause AWDA10923- The University and the vendor performing the biomarker storage have a long-standing relationship dating back to a subaward beginning in fiscal year 2013. After the completion of the subaward, the University continued to use the vendor for maintenance for biomarker storage. Due to the long-standing relationship between the University and this vendor, the department did not realize price quotations needed to be obtained or sole source documentation completed. AWD0003614- The PI was not aware of the small purchase threshold and Yale?s policy to request price quotations for purchases of $10,000 or greater. Therefore, when the PI contracted with the consulting group, no price quotations or sole source documentation was obtained. Effect Deficiencies in the controls surrounding procurement could result in non-compliance with the federal awarding agency and potential reduction in funding in future years.Recommendation Given that there were two instances of purchases that met the University?s small purchase threshold where there were no price quotations obtained or sole source documentation provided, we recommend that the University provide additional training to faculty and staff on the University?s purchasing approval requirements. We also recommend the University route purchases through the Procurement department when appropriate. Management?s Views and Corrective Action Plan Management's views and corrective action plan is included at the end of the report after the summary schedule of prior audit findings and status.

Finding No. 2020-002 ? E-Sign Act Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Perkins Loan, Federal Pell Grant, Federal Direct Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professional Student Loans, Nursing Student Loan Award Year: FY2020 CFDA Number: 84.007, 84.033, 84.038, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The Electronic Signatures in Global and National Commerce Act (?E-Sign Act?) states that a school must obtain a student?s voluntary consent to participate in electronic transactions. Condition In examining 60 student records, we noted that the University requires each student annually agree to certain terms and conditions before they accept federal student assistance, however, a statement prompting the student to voluntarily consent to participate in electronic transactions was not included in the list of terms and conditions. Questioned Costs None noted. Cause The University inadvertently omitted the statement prompting the student to voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation We recommend the University add a statement that the student voluntarily consents to participating in electronic transactions to the list of terms and conditions annually agreed to by students receiving federal student financial assistance. Management?s Views and Corrective Action Plan Management's views and corrective action plan is included at the end of the report after the summary schedule of prior audit findings and status.

Finding No. 2020-003 ? Allowable Costs/Cost Principles Award Information Cluster: Research & Development (R&D) Grantor: US Department of Energy (DOE), National Institute of Mental Health (NIMH)/NIH/DHHS Award Name: Oxomanganese Catalysts for Solar Fuel Production, Somatic Mosaicism in the Brain of Tourette Syndrome Award Year: September 1, 2019 ? February 29, 2020 (AWDE00110); February 1, 2019 - January 31, 2020 (AWDA10986) CFDA Number: 81.049, Office of Science Financial Assistance Program; 93.242, Mental Health Research Grants Criteria Yale?s policy 1104 on approval authority reads as follows; ?For sponsored awards, Initiators/Requestors other than the Principal Investigator must be authorized by the Principal Investigator (?PI?) to initiate transactions on the account. The authorization must be documented in the award file.? Condition We selected 29 non-compensation expenditure transactions totaling $597,812 for direct cost testing within the R&D cluster and noted two selections totaling $149,437 that were initiated by a graduate student and a postdoc associate working on the awards and neither of these individuals had been delegated approval authority under the respective awards. However, these expenditures were in compliance in terms of allowability. Questioned Costs None noted. Cause AWDE00110- The expenditure was initiated by a graduate student working on the award who was not familiar with the Yale policy on initiating of federal expenditures. AWDA10986- The expenditure was initiated by a Postdoc Associate in the lab who was not familiar with the Yale policy on initiating of federal expenditures. Effect Deficiencies in the controls surrounding direct costs could result in inappropriate charges being made to the award, causing non-compliance with the federal awarding agency and potential reduction in funding in future years. Recommendation We recommend that the University provide additional training to staff on the appropriate approval authority and documentation that is required to be on file prior to initiating a charge. Management?s Views and Corrective Action Plan Management's views and corrective action plan is included at the end of the report after the summary schedule of prior audit findings and status.

Award InformationCluster: Research & Development (R&D)Grantor: National Institutes of Health (NIH)Award Name: Yale Diabetes Research CenterAward Year and Award Number: March 1, 2018 ? January 31, 2023 (AWD0001157)CFDA Number: 93.847 Diabetes, Digestive, and Kidney Diseases Extramural ResearchCriteria2 CFR 200.405 states that a cost is allocable to a particular Federal award or other cost objective if thegoods or services involved are incurred specifically for the Federal award. Additionally, 2 CFR 200.423states that costs of alcoholic beverages are unallowable.ConditionWe selected 60 transactions for allowability testing within the R&D cluster and noted one selection wherea meal, totaling $410, which included a partial charge for alcohol, was charged to the award for a guestspeaker and other University personnel. The only portion of the charge that was allowable under the grantwas the speaker?s meal, however, the University was unable to identify which portion of the meal relatedto the guest speaker. The other University personnel that attended the dinner were not directly involved inthe grant. As such their meals were unallowable.Questioned Costs$410CauseAn itemized receipt from the dinner was reviewed and approved, however, both individuals inadvertentlyoverlooked during the review that the cost of the meal should not be charged for those not directlyinvolved in the award.EffectDeficiencies in the controls surrounding compliance over allowability could result in non-compliance withthe federal awarding agency and potential reduction in funding in future years.RecommendationGiven that this was due to human error and an isolated incident, we recommend that the Universitycontinue to provide additional training to staff on what to look for during their reviews. Additionally, theunallowable costs should be removed from the award.

Finding No. 2019-002 ? General Terms and Provisions ? Acknowledgement of Federal Funding inPublicationsAward InformationCluster: Research & Development (R&D)Grantor: National Institutes of Health (NIH)Award Name and Award Number: Systems analysis of phenotypic switch in control of cancer invasion(AWDA10781), Structural Bases of the Functions of RNA-Protein Machines (AWDA10358)Award Year: August 8, 2016 ? July 31, 2019 (AWDA10781), July 1, 2015 ? March 31, 2020(AWDA10358)CFDA Number: 93.397 Cancer Center Support Grants (AWDA10781), 93.859 Biomedical Research andResearch Training (AWDA10358)CriteriaGeneral Terms ? PublicationsEach publication, press release, or other document about research supported by the NIH award mustinclude an acknowledgement of NIH award support and a disclaimer such as "Research reported in thispublication was supported by the National Institute of General Medical Sciences of the National Institutesof Health under Award Number 5P01GM022778 (AWDA10358) and 1U54CA209992 (AWDA10781). Thecontent is solely the responsibility of the authors and does not necessarily represent the official views ofthe National Institutes of Health.?ConditionWe selected 60 allowability charges within the R&D cluster and noted two selections where the federalfunding sources were not cited in accordance with the general term restrictions in the grant agreementsand did not include the disclaimer included within the award agreement (AWDA10358 and AWDA10781).The general terms were as follows:a) AWDA10358 - The PI published one paper during the award year. In the publication the followingwas included as a source of funding: ?This work was supported by National Institutes of HealthGrant GM022778.? As such, all of the required disclosures were not made in the publications.b) AWDA10781 - The PI published one paper during the award year. In the publication the followingwas included as a source of funding: ?Yale Cancer Center Co-Pilot Grant {U54CA193461 to R.F.,U54CA209992, Sub-Project ID: 7297 to R.F,}.? As such, all of the required disclosures were notmade in the publications.CauseOffice of Sponsored Projects (?OSP?) notified the PIs and the department business offices (?DBO?) of theawards? general terms and restrictions. This notification was accomplished via email with a copy of theNotice of Award (?NOA?) attached to the email. OSP?s notification to the PI and DBO is part of its awardset-up standard operating procedure. Due to inadvertent oversight, the PIs responsible for the awards didnot comply with the notification requirements. EffectDeficiencies in the controls surrounding compliance over special terms and provisions could result in noncompliancewith the federal awarding agency and potential reduction in funding in future years.RecommendationWe recommend that the University review and enhance the controls in place over the tracking andacknowledgement of federal funding in publications. In addition, we recommend that the Universityperiodically remind PIs of the importance of citing funding sources within publications.

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