EIN: 231365971
UEI: QD4MGHFDJKU1
Data as of August 25, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 31, 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 October 1, 2026 (36 days from today).
What is a management decision? →FINDING 2025-001 Significant Deficiency in Internal Control Over Compliance – Cash Management Federal Agency: Department of Health and Human Services Pass-through Grantor: Pennsylvania Department of Health Federal Program: Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Assistance Listing Number: 93.391 Criteria: Non-federal entities must establish written procedures to implement the requirements of 2 CFR 200.305 (2 CFR 200.302(b)(6)). As such, per the grant’s terms and conditions and 2 CFR Part 200, the University is to request reimbursement for allowable costs incurred associated with the award. Per the grant’s terms and conditions and per 2 CFR Part 200 Uniform Guidance principles of allowability, allocability, and reasonableness, invoiced costs must: Be consistent with the approved budget or supported by an approved budget revision Further, per 2 CFR 200.303, the recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal award. (c) Evaluate and monitor the recipient's or subrecipient's compliance with statutes, regulations, and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified. Condition/Context: During the year ended June 30, 2025, Temple University identified certain instances where the invoices submitted to the granting agency for expenditure activity associated with the year ended June 30, 2024 which did not accurately reflect costs incurred, certain costs were reclassified on the invoice in order to align with budgetary constraints. The University invoices the Pennsylvania Department of Health (PADOH), the pass-through entity, for reimbursement of allowable costs incurred under the award, with expenditures tracked and billed by approved budget category. During the normal course of operations, the University’s Internal Audit function identified discrepancies in the invoicing process in which certain expenses were inappropriately reclassified from a budget category that had exceeded the approved amount to another category with remaining budget; the issue was corrected, communicated to PADOH, and subsequently communicated to D&T. Cause: The invoicing process lacked appropriate segregation of duties as well as effective preventive and detective controls to mitigate the inaccurate reporting of expenditure activity to the granting agency. The control process did not have: • Adequate segregation of duties and review of invoice amounts against the approved award budget and supporting expenditure detail • Adequate exception monitoring and reporting for unusual budget line activity: Effect: As a result of this ineffective control process, the invoices submitted to the granting agency did not accurately represent expenditure activity for the period and cumulative expenditure activity for the fiscal year. Inaccurate reporting to the granting agency could result in the University not receiving funding from the granting agency in future years, the granting agency identifying questioned costs or disallowances which could result in the University being required to reimburse the granting agency for such questioned costs, and increased oversight or special award conditions from the granting agency. Questioned Costs: None. Recommendation: We recommend the University evaluate control owners to determine that proper segregation of duties and oversight is present with invoicing. We recommend the University strengthen controls over grant invoicing and budget-to-actual monitoring to ensure costs are consistently billed in accordance with the award’s approved budget categories and that any required reclassifications are appropriate, documented, reviewed, and approved by the granting agency, preferably via a budget amendment, prior to submission. Repeat Finding: No. Views of Responsible Officials: University management agrees with the evaluation. Management. emphasized that University Internal Audit identified the invoicing error and promptly investigated the matter, including notifying Deloitte & Touche LLP as the external auditor. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2025-001 Significant Deficiency in Internal Control Over Compliance – Cash Management Federal Agency: Department of Health and Human Services Pass-through Grantor: Pennsylvania Department of Health Federal Program: Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Assistance Listing Number: 93.391 Criteria: Non-federal entities must establish written procedures to implement the requirements of 2 CFR 200.305 (2 CFR 200.302(b)(6)). As such, per the grant’s terms and conditions and 2 CFR Part 200, the University is to request reimbursement for allowable costs incurred associated with the award. Per the grant’s terms and conditions and per 2 CFR Part 200 Uniform Guidance principles of allowability, allocability, and reasonableness, invoiced costs must: Be consistent with the approved budget or supported by an approved budget revision Further, per 2 CFR 200.303, the recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal award. (c) Evaluate and monitor the recipient's or subrecipient's compliance with statutes, regulations, and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified. Condition/Context: During the year ended June 30, 2025, Temple University identified certain instances where the invoices submitted to the granting agency for expenditure activity associated with the year ended June 30, 2024 which did not accurately reflect costs incurred, certain costs were reclassified on the invoice in order to align with budgetary constraints. The University invoices the Pennsylvania Department of Health (PADOH), the pass-through entity, for reimbursement of allowable costs incurred under the award, with expenditures tracked and billed by approved budget category. During the normal course of operations, the University’s Internal Audit function identified discrepancies in the invoicing process in which certain expenses were inappropriately reclassified from a budget category that had exceeded the approved amount to another category with remaining budget; the issue was corrected, communicated to PADOH, and subsequently communicated to D&T. Cause: The invoicing process lacked appropriate segregation of duties as well as effective preventive and detective controls to mitigate the inaccurate reporting of expenditure activity to the granting agency. The control process did not have: • Adequate segregation of duties and review of invoice amounts against the approved award budget and supporting expenditure detail • Adequate exception monitoring and reporting for unusual budget line activity: Effect: As a result of this ineffective control process, the invoices submitted to the granting agency did not accurately represent expenditure activity for the period and cumulative expenditure activity for the fiscal year. Inaccurate reporting to the granting agency could result in the University not receiving funding from the granting agency in future years, the granting agency identifying questioned costs or disallowances which could result in the University being required to reimburse the granting agency for such questioned costs, and increased oversight or special award conditions from the granting agency. Questioned Costs: None. Recommendation: We recommend the University evaluate control owners to determine that proper segregation of duties and oversight is present with invoicing. We recommend the University strengthen controls over grant invoicing and budget-to-actual monitoring to ensure costs are consistently billed in accordance with the award’s approved budget categories and that any required reclassifications are appropriate, documented, reviewed, and approved by the granting agency, preferably via a budget amendment, prior to submission. Repeat Finding: No. Views of Responsible Officials: University management agrees with the evaluation. Management. emphasized that University Internal Audit identified the invoicing error and promptly investigated the matter, including notifying Deloitte & Touche LLP as the external auditor. See Corrective Action Plan.
Corrective Action Plan FINDING 2025-001 Planned Corrective Action: The award period ended on June 30, 2025. Management performed a comprehensive re-review of invoices associated with FY25 billings to confirm that amounts submitted for reimbursement were accurately presented and that cumulative expenditures remained within approved budget limits. In connection with this review, the University identified invoiced amounts associated with incorrectly classified budget categories and has refunded $243,852.41 to the Pennsylvania Department of Health (PADOH) in full. To address the identified control deficiencies and prevent recurrence, the University has implemented and continues to formalize enhanced controls over the grant invoicing process. These actions establish appropriate segregation of duties, strengthen pre-submission review procedures, and enhance monitoring of budget-to-actual expenditures. Effective immediately, the University has centralized invoice preparation and submission within the post-award office. Departments are no longer permitted to submit invoices directly to sponsors. All invoices must be prepared, reviewed, and submitted by a post-award grant analyst. This control establishes clear ownership and appropriate segregation of duties between transaction processing and independent review. As part of the enhanced review process, all invoices are subject to a documented pre-submission review to: (1) reconcile invoice line items to the underlying general ledger detail, and (2) compare year-to-date expenditures to the approved award budget by category to ensure allowability, accuracy, and compliance with budget constraints. Additionally, all invoices are digitally signed by the reviewing post-award grant analyst prior to submission, providing evidence of review and creating an auditable record of approval. The University is further strengthening preventive and detective controls by developing a formal grant invoicing policy and enhancing monitoring processes. The formal policy will codify roles and responsibilities for invoice preparation, review, approval, and submission; require documented budget-to-actual monitoring; and require that any reallocation of costs between approved budget categories be supported by sponsor approval, preferably through a formal budget amendment, prior to invoice submission. In addition, the University is implementing an enhanced invoice-tracking and monitoring process within the post-award office to ensure that all expected invoices are prepared, reviewed, and submitted through the appropriate control structure. This process will include identifying and investigating exceptions, such as instances where invoicing activity does not align with expected billing patterns, to support the timely detection and resolution of discrepancies. Collectively, these actions strengthen internal controls over compliance with federal award requirements, improve accuracy and transparency in financial reporting to sponsors, and address the root causes identified in the finding. Anticipated Completion Date: June 30, 2026 Responsible Contact Person: Josh Gladden, Vice President for Research
FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.
Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Show full finding ▾Hide full finding ▴Reference Number: 2024-001 Federal Agency: National Institutes of Health Federal Program: Research and Development Cluster Pass-through: University of Pennsylvania; University of Alabama at Birmingham ALN Number: 93.242; 93.279; and 93.847 Contract numbers: # 5RO1-MH-128155-03; 1DP2DA056172-01; K01DA046308; 5R01DK108438-05 Compliance Requirement: Equipment and Real Property Management Type of Finding: Deficiency-Non-Compliance (1) CRITERIA Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management; Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: • Equipment, including replacement equipment, be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award or, when appropriate, under other federal awards; however, the non-federal enity must not encumber the equipment without prior approval of the federal awarding agency (2 CFR sections 200.313(c) and (e)). • When original or replacement equipment acquired under a federal award is no longer needed for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency if required by the terms and conditions of the award. Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further obligation to the federal awarding agency. If the federal awarding agency fails to provide requested disposition instructions within 120 days, items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold. The federal awarding agency is entitled to the federal interest in the equipment, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs (2 CFR section 200.313(e)). (2) CONDITION/PERSPECTIVE The University has policies and procedures regarding Equipment and Real Property management. We tested the Research and Development Cluster; Program’s - Novel Macrophage-Tropic Transmited Founder Shiv Model Of CNS Persistence To Evaluate CrsprCas9 Gene Editing (ALN # 93.242) ; HIV and Cocaine Drive Bone-Marrow Blood (BMB) Barrier Dysfunction and Altered Hematopoitic Stem Cell (HSC) Differentiation Leading to Chronic Immune Activation (ALN # 93.279); Role of Patrolling Monocytes in Cerebral Vascular Repair during HIV Substance Abuse (ALN # 93.279); Effect Of Pitavastatin On Kidney Function In HIV-Infected Persons (ALN # 93.847) Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the original Project was transferred to another University. We noted that out of 40 samples selected for equipment compliance test, 4 equipment value greater than $5,000 was also transferred to another University. The Program investigator carried the equipment assigned to another University where the project was transferred. The university did not obtain disposition instructions from the funding agency. (3) CAUSE The University did not obtain disposition instructions from the funding agency of transfer of Equipment to another university. (4) EFFECT The University may be considered non-compliant related to Equipment and Real Property management compliance as required by 2 CFR section 200.313©. (5) REPEAT FINDING No (6) QUESTIONED COST Cannot be determined. (7) RECOMMENDATION When original or replacement equipment acquired under a federal award is no longer needed or transferred for a federal program (whether the original project or program or other activities currently or previously supported by the federal government), the non-federal entity must request disposition instructions from the federal awarding agency. (8) VIEWS OF RESPONSIBLE OFFICIAL Temple concurs with the finding. We have already reached out to the specified sponsors to provide documentation about the equipment that was transferred along with the award and requesting retroactive dispostion instructions. We are also conducting a review of all transferred awards that have occurred in the past fiscal year, to determine if any of them have a similar situation. Temple will update its equipment management policy to explicitly address procedures for equipment transfers between institution. Additionally, we will add equipment transfers as an explicit item in our PI transfer checklist. We will also update the training program provided to equipment managers to address transferring of equipment. Also, see “Corrective Action Plan”.
Corrective Action Plan: Temple concurs with the finding and has contacted the specified sponsors to obtain specific required documentation on transferred equipment and request retroactive disposition instructions. To improve compliance, Temple will update its equipment management policy to include procedures for equipment transfers between institutions. Equipment transfers will also be added to the internal PI transfer checklist. Additionally, we will enhance the training program for equipment managers to cover equipment transfer procedures. Action Date: March 24, 2025 Final Implementation Date: May 31, 2025 Name And Phone Number of Person Responsible for Implementation: Josh Gladden, (215) 204-370- 8138 See " Corrective Plan" on pages 127-128
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