EIN: 131624046
UEI: G3XNCEEELQN3
Audited by: Grant Thornton LLP
Cognizant agency: 19 [Department of State]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 11, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by December 11, 2026 (104 days from today).
What is a management decision? →FAC accepted this audit on June 3, 2025 — management decision was due December 3, 2025.
FAC accepted this audit on June 6, 2024 — management decision was due December 6, 2024.
FAC accepted this audit on June 14, 2023 — management decision was due December 14, 2023.
FAC accepted this audit on June 19, 2022 — management decision was due December 19, 2022.
FAC accepted this audit on June 24, 2021 — management decision was due December 24, 2021.
Finding 2020-001: Allowable Costs/Costs Principles ? Cost Transfers (Significant Deficiency) Federal Agency: Bureau of Educational and Cultural Affairs of the U.S. Department of State See Schedule of Findings and Questions Costs for chart/table Criteria or specific requirement The Uniform Guidance requires that non-federal entities establish written accounting procedures and policies that support the accumulation of costs consistent with the cost principles delineated in Subpart E. IIE?s cost transfer policy states that the purpose of the policy is to support regulatory compliance on cost with respect to allowability, reasonableness, and allocability. While not explicitly required in the relevant regulations, IIE includes a general timeframe in which cost transfers must be processed (generally within 90 days after the initial charge), and additional approval requirements for circumstances where that timeframe is surpassed. IIE?s cost transfer policy includes requirements for the documentation and approval that must accompany cost transfers. Condition For the Fulbright Student and Scholar Programs, we selected a sample of cost transfers for testing. Our sample included both payroll and non-payroll corrections/re-distributions. We noted the following with regards to the samples selected for testing: See Schedule of Findings and Questioned Costs for chart/table. Questioned costs There are no questioned costs associated with this finding as the costs transferred were allowable and allocable to the awards to which they were transferred. Effect Cost transfers were processed outside of the timeframe referenced in IIE?s policy, which requires additional approval. IIE did obtain the additional approval for those cost transfers. IIE?s cost transfer policy states, ?transfers completed more than 90 days after initial charge are allowed but require Controller approval?. Cause Management has a cost transfer policy which includes a general timeframe during which cost transfers must be approved by the Controller (over 90 days). While the policy states that items requiring correction should be identified, corrected, and documented in a timely and consistent manner, there were cost transfers processed after 90 days, which received the required internal approval. Costs were initially miscoded to an award and were not identified and transferred until after 90 days from initial charge. Recommendation We recommend management continue to educate staff on the cost transfer policy, with a specific emphasis on the importance of processing costs to the correct contract. In addition, we recommend management continue to implement a monthly review of costs for timely detection and processing of any necessary cost transfers. Views of responsible officials and planned corrective actions Refer to management?s corrective actions on page 36.
Show full finding ▾Hide full finding ▴Finding 2020-001: Allowable Costs/Costs Principles ? Cost Transfers (Significant Deficiency) Federal Agency: Bureau of Educational and Cultural Affairs of the U.S. Department of State See Schedule of Findings and Questions Costs for chart/table Criteria or specific requirement The Uniform Guidance requires that non-federal entities establish written accounting procedures and policies that support the accumulation of costs consistent with the cost principles delineated in Subpart E. IIE?s cost transfer policy states that the purpose of the policy is to support regulatory compliance on cost with respect to allowability, reasonableness, and allocability. While not explicitly required in the relevant regulations, IIE includes a general timeframe in which cost transfers must be processed (generally within 90 days after the initial charge), and additional approval requirements for circumstances where that timeframe is surpassed. IIE?s cost transfer policy includes requirements for the documentation and approval that must accompany cost transfers. Condition For the Fulbright Student and Scholar Programs, we selected a sample of cost transfers for testing. Our sample included both payroll and non-payroll corrections/re-distributions. We noted the following with regards to the samples selected for testing: See Schedule of Findings and Questioned Costs for chart/table. Questioned costs There are no questioned costs associated with this finding as the costs transferred were allowable and allocable to the awards to which they were transferred. Effect Cost transfers were processed outside of the timeframe referenced in IIE?s policy, which requires additional approval. IIE did obtain the additional approval for those cost transfers. IIE?s cost transfer policy states, ?transfers completed more than 90 days after initial charge are allowed but require Controller approval?. Cause Management has a cost transfer policy which includes a general timeframe during which cost transfers must be approved by the Controller (over 90 days). While the policy states that items requiring correction should be identified, corrected, and documented in a timely and consistent manner, there were cost transfers processed after 90 days, which received the required internal approval. Costs were initially miscoded to an award and were not identified and transferred until after 90 days from initial charge. Recommendation We recommend management continue to educate staff on the cost transfer policy, with a specific emphasis on the importance of processing costs to the correct contract. In addition, we recommend management continue to implement a monthly review of costs for timely detection and processing of any necessary cost transfers. Views of responsible officials and planned corrective actions Refer to management?s corrective actions on page 36.
June 2, 2021 PricewaterhouseCoopers LLP 300 Madison Avenue New York, NY 10017 RE: Fiscal Year 2020 Findings Dear PricewaterhouseCoopers: Below please find IIE?s response and corrective action plan for the finding contained in the fiscal year 2020 financial statements and uniform guidance audit. Views of responsible officials and planned corrective actions As noted by PWC, none of these transfers are questioned on the grounds of allowability or allocability; the transfers were the correct action to take, and this finding relates solely to the timeliness of the transfers. IIE remains committed to ensuring costs are recorded in accordance with all regulatory and award requirements. Therefore, upon conclusion of the FY2019 audit in late June 2020, IIE implemented several measures to increase employee awareness and knowledge and closely monitor cost transfers. A mandatory training for all team members on coding and cost transfers was released in July 2020 and completed by all team members by August 31, 2020. It has been available on IIE?s learning platform since its release and the training was incorporated into the onboarding process. New team members are required to complete the coding and cost transfer training within five business days of starting employment at IIE. In June 2020, we also implemented a monthly certification for team members who approve or process payments to confirm that team members have processed any necessary cost transfers. Additionally, the Program Finance & Business Analytics team (PFA) documents all cost transfers over 90 days, including identifying the root cause of the transfer and any opportunities for process improvements. In early June 2020, the IIE Executive Team met with the Senior Director of PFA to review all cost transfers fiscal year to date in FY2020. Starting with the June 2020 month close, IIE has met to review monthly cost transfers over 90 days. As a result of the above efforts, IIE has seen improvements in coding and cost transfer timing and will continue implementing best practices, including: mandatory training; regular certifications; and regular financial reviews, including root cause analysis. Institute of International Education ? iie.org One World Trade Center, 36th Floor ? New York, NY 10007 IIE will: ? Conduct another mandatory training for all IIE team members on coding and cost transfers. In the trainings, we will review IIE?s Cost transfer policy, emphasize the importance and impact of coding, give an overview of the financial coding and monitoring tools that IIE team members are expected to use, review industry best practices and connect team members to additional trainings and tools available at IIE for further development according to their role. This training will be completed by September 30, 2021, will continue to be available in a recorded format on IIE?s learning platform, and will continue to be required for new employees during onboarding. ? Continue the certification process. Team members who process or approve payments or manage budgets will certify on a regular basis that they have processed any cost transfers identified in the prior month. ? Continue to hold regular financial review meetings to monitor expenses by program and track any required cost transfers. In these meetings, finance and program leadership will review expenditures, identify and track any necessary cost transfers, and review any need for employee education or follow up. We will continue to utilize reporting tools, such as Microsoft? Power BI, to enhance our reporting capabilities. For any cost transfer not processed in a timely manner, IIE will analyze the root cause and take remedial action as may be necessary. Sincerely, Jason Czyz Executive VP and Chief Financial Officer
2019-001
FAC accepted this audit on June 24, 2020 — management decision was due December 24, 2020.
Finding 2019-001: Allowable Costs/Costs Principles ? Cost Transfers (Significant Deficiency) Federal Agency: Bureau of Educational and Cultural Affairs of the U.S. Department of State; U.S. Department of Defense Criteria or specific requirement The Uniform Guidance requires that non-federal entities establish written accounting procedures and policies that support the accumulation of costs consistent with the cost principles delineated in Subpart E. IIE?s cost transfer policy states that the purpose of the policy is to support regulatory compliance on cost with respect to allowability, reasonableness, and allocability. While not explicitly required in the relevant regulations, IIE includes a general timeframe in which cost transfers must be processed (generally within 90 days after the initial charge), and additional approval requirements for circumstances where that timeframe is surpassed. IIE?s cost transfer policy includes requirements for the documentation and approval that must accompany cost transfers as well as the general timeframe in which cost transfers must be processed (generally within 90 days after the initial charge). Condition For the Fulbright Student Program and ROTC Language and Culture Project, we selected a sample of thirty-one cost transfers for testing. Our sample included both payroll and non-payroll corrections/re-distributions. We noted the following with regards to the samples selected for testing: Fulbright Student Program Total Expenditures Fiscal Year 2019 = $81,608,529 Total Net Cost Transfers in FY2019 = $1,299,368 Total Gross Amount of Cost Transfers Selected for Testing = $348,366 Total Sample Selections = 25 Total Gross Amount of Transfers >90 Days in Sample Selection Noted as Exceptions = $204,596 Total Sample Selections > 90 Days Noted as Exceptions = 7 Average Days Outstanding for Selections > 90 Days Noted as Exceptions = 343 ROTC Language and Culture Project Total Expenditures Fiscal Year 2019 = $14,984,056 Total Net Cost Transfers in FY2019 = $6,553 Total Gross Amount of Cost Transfers Selected for Testing = $247,581 Total Sample Selections = 6 Total Gross Amount of Transfers >90 Days in Sample Selection Noted as Exceptions = $212,467 Total Sample Selections > 90 Days Noted as Exceptions = 4 Average Days Outstanding for Selections > 90 Days Noted as Exceptions = 169 Questioned costs There are no questioned costs associated with this finding as the costs transferred were allowable and allocable to the awards to which they were transferred. Effect Cost transfers are processed outside of the timeframe referenced in IIE?s policy (greater than 90 days). Cause Management has a cost transfer policy which includes a general timeframe during which cost transfers should be detected and processed (generally 90 days). While the policy states that items requiring correction should be identified, corrected, and documented in a timely and consistent manner (generally 90 days), there were cost transfers processed in excess of the stated timeframe. For these two programs, costs were initially miscoded to an incorrect award or incorrect expense accounts within an award and were not identified and transferred until after the suggested 90 days in IIE?s policy. Recommendation We recommend management educate staff on the cost transfer policy, with a specific emphasis on the importance of processing costs to the correct contract. In addition, we recommend management implement a monthly review of costs for timely detection and processing of any necessary cost transfers. Views of responsible officials and planned corrective actions Refer to management?s corrective actions on page 37.
Show full finding ▾Hide full finding ▴Finding 2019-001: Allowable Costs/Costs Principles ? Cost Transfers (Significant Deficiency) Federal Agency: Bureau of Educational and Cultural Affairs of the U.S. Department of State; U.S. Department of Defense Criteria or specific requirement The Uniform Guidance requires that non-federal entities establish written accounting procedures and policies that support the accumulation of costs consistent with the cost principles delineated in Subpart E. IIE?s cost transfer policy states that the purpose of the policy is to support regulatory compliance on cost with respect to allowability, reasonableness, and allocability. While not explicitly required in the relevant regulations, IIE includes a general timeframe in which cost transfers must be processed (generally within 90 days after the initial charge), and additional approval requirements for circumstances where that timeframe is surpassed. IIE?s cost transfer policy includes requirements for the documentation and approval that must accompany cost transfers as well as the general timeframe in which cost transfers must be processed (generally within 90 days after the initial charge). Condition For the Fulbright Student Program and ROTC Language and Culture Project, we selected a sample of thirty-one cost transfers for testing. Our sample included both payroll and non-payroll corrections/re-distributions. We noted the following with regards to the samples selected for testing: Fulbright Student Program Total Expenditures Fiscal Year 2019 = $81,608,529 Total Net Cost Transfers in FY2019 = $1,299,368 Total Gross Amount of Cost Transfers Selected for Testing = $348,366 Total Sample Selections = 25 Total Gross Amount of Transfers >90 Days in Sample Selection Noted as Exceptions = $204,596 Total Sample Selections > 90 Days Noted as Exceptions = 7 Average Days Outstanding for Selections > 90 Days Noted as Exceptions = 343 ROTC Language and Culture Project Total Expenditures Fiscal Year 2019 = $14,984,056 Total Net Cost Transfers in FY2019 = $6,553 Total Gross Amount of Cost Transfers Selected for Testing = $247,581 Total Sample Selections = 6 Total Gross Amount of Transfers >90 Days in Sample Selection Noted as Exceptions = $212,467 Total Sample Selections > 90 Days Noted as Exceptions = 4 Average Days Outstanding for Selections > 90 Days Noted as Exceptions = 169 Questioned costs There are no questioned costs associated with this finding as the costs transferred were allowable and allocable to the awards to which they were transferred. Effect Cost transfers are processed outside of the timeframe referenced in IIE?s policy (greater than 90 days). Cause Management has a cost transfer policy which includes a general timeframe during which cost transfers should be detected and processed (generally 90 days). While the policy states that items requiring correction should be identified, corrected, and documented in a timely and consistent manner (generally 90 days), there were cost transfers processed in excess of the stated timeframe. For these two programs, costs were initially miscoded to an incorrect award or incorrect expense accounts within an award and were not identified and transferred until after the suggested 90 days in IIE?s policy. Recommendation We recommend management educate staff on the cost transfer policy, with a specific emphasis on the importance of processing costs to the correct contract. In addition, we recommend management implement a monthly review of costs for timely detection and processing of any necessary cost transfers. Views of responsible officials and planned corrective actions Refer to management?s corrective actions on page 37.
June 23, 2020 PricewaterhouseCoopers LLP 300 Madison Avenue New York, NY 10017 RE: Fiscal Year 2019 Findings Dear PricewaterhouseCoopers: Below please find IIE?s response and corrective action plan for the finding contained in the fiscal year 2019 financial statements and uniform guidance audit. Views of responsible officials and planned corrective actions As noted by PWC, none of these transfers are questioned on the grounds of allowability or allocability; the transfers were the correct action to take and this finding relates solely to the timeliness of the transfers. IIE is committed to ensuring costs are recorded in accordance with all regulatory and award requirements. Upon conclusion of the FY2018 audit in late June 2019, IIE implemented mandatory training for all team members on coding and cost transfers. IIE also developed new tools using Microsoft? Power BI, which allows the IIE team members to have dynamic visibility into the costs in close to real time. This has been useful in managing complicated awards with many transactions and participants funded through various sources. This robust tool provides both management-level and detailed grantee-level reporting for insight and discussion in regular financial meetings. Since the implementation of these measures occurred in the last quarter of FY2019 and beginning of FY2020, the results of these efforts are not seen in FY2019. In response to this finding, IIE will: ? Conduct another mandatory training for all IIE team members on coding and cost transfers. In the trainings, we will review IIE?s Cost transfer policy, emphasize the importance and impact of coding, give an overview of the financial coding and monitoring tools that IIE team members are expected to use, review industry best practices and connect people to additional trainings and tools available at IIE for further development according to their role. This training will be completed by December 31, 2020 ? The training will continue to be available in an interactive recorded format on IIE?s learning platform and will be required for new employees during onboarding. ? IIE will implement a certification from team members that they have processed any necessary cost transfers. Team members who process or approve payments or manage budgets will certify on a regular basis that they have processed any cost transfers identified in the prior month and that all budget reviews have been completed. This will be completed by August 31, 2020 ? IIE will hold regular financial review meetings to monitor expenses by program and track any required cost transfers. For any cost transfer not processed in a timely manner, IIE will analyze the root cause and take remedial action as may be necessary. In these meetings, finance and program leadership will review expenditures, identify and track any necessary cost transfers, and review any need for employee education or follow up. We will continue to utilize reporting tools, such as Microsoft? Power BI, to enhance our reporting capabilities. These meetings will begin with the June 2020 monthly accounting close. Sincerely, Jason Czyz Executive VP and Chief Financial Officer
2018-002
FAC accepted this audit on June 25, 2019 — management decision was due December 25, 2019.
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FAC accepted this audit on January 11, 2019 — management decision was due July 11, 2019.
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2016-001
FAC accepted this audit on December 19, 2017 — management decision was due June 19, 2018.
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