Case Western Reserve UniversityHigher Education

EIN: 341018992

UEI: HJMKEF7EJW69

Audited by: PriceWaterhouseCoopers LLP

Cognizant agency: 93 [Department of Health and Human Services]

Data as of August 28, 2026

Case Western Reserve University11 audit years17 findings5 repeat
11
Audit Years
17
Total Findings
5
Repeat Findings

FY 2025-06-30

GOING CONCERNLOW-RISK AUDITEE$648,717,796 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 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 September 11, 2026 (14 days from today).

What is a management decision? →
2025-001
Cash Management
REPEATOTHER MATTERS

Criteria In accordance with 2 CFR 200.302 (b)(3), the recipient must maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition We selected 25 drawdowns across all agencies for testing. Of these 25, 1 drawdown selection was approved 1 day after the drawdown request was submitted, but prior to receiving the draw amount. However, this 1 drawdown selection was prior to the remediation period performed by management. As such, it is included as a repeat finding, but as there were no exceptions in the remediation period, the finding is considered remediated. Cause During the audit period, the University experienced a transition in leadership within the Office of Research Administration. As part of this transition, the Associate Vice President for Research Administration was responsible for reviewing and approving drawdown requests, which was overlooked in certain instances. Effect The University processed drawdowns prior to supervisory approval. Questioned Costs None. Repeat Finding Yes Recommendation We recommend management revisit existing internal control procedures to ensure requested reimbursements are approved prior to the request

Show full finding ▾
Full finding narrative

Criteria In accordance with 2 CFR 200.302 (b)(3), the recipient must maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition We selected 25 drawdowns across all agencies for testing. Of these 25, 1 drawdown selection was approved 1 day after the drawdown request was submitted, but prior to receiving the draw amount. However, this 1 drawdown selection was prior to the remediation period performed by management. As such, it is included as a repeat finding, but as there were no exceptions in the remediation period, the finding is considered remediated. Cause During the audit period, the University experienced a transition in leadership within the Office of Research Administration. As part of this transition, the Associate Vice President for Research Administration was responsible for reviewing and approving drawdown requests, which was overlooked in certain instances. Effect The University processed drawdowns prior to supervisory approval. Questioned Costs None. Repeat Finding Yes Recommendation We recommend management revisit existing internal control procedures to ensure requested reimbursements are approved prior to the request

Corrective Action Plan

The University acknowledges the audit finding and remains committed to maintaining compliance with the cash management requirements outlined in 2 CFR 200.302 (b)(3), which stipulates that recipients must maintain records that sufficiently identify Federal awards and ensure that drawdowns are properly supported and authorized prior to submission. During the audit period, at least one drawdown was approved, one day retroactively, after submission but prior to receipt of funds. This occurred prior to the remediation period. No exceptions were identified in the remediation period, and the finding is considered remediated. The instance arose during a leadership transition with the Office of Research Administration. Since that time, the entire drawdown process, review and approval has been clarified under new leadership, and additional oversight has been implemented to ensure approvals are documented prior to submission. As part of the drawdown process review, the University developed a standardized drawdown template, which streamlines how the Federal award expense information is gathered, compared to approve budgeted amounts and reviewed for approval. The template documents the preparer, the approver and the dates of both for the respective drawdown. The Office of Research Administration received training on the use of the template in January and February 2026 and implementation is planned for February 2026. Primary responsibility for implementing the correction action plan for this finding rests with Angela Tagliaferri, Assistant Vice President of Post-Award Services and Financial Compliance, 216-368-6269.

Prior Finding References

2024-003

About Cash Management →
2025-001
Cash Management
REPEATOTHER MATTERS

Criteria In accordance with 2 CFR 200.302 (b)(3), the recipient must maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition We selected 25 drawdowns across all agencies for testing. Of these 25, 1 drawdown selection was approved 1 day after the drawdown request was submitted, but prior to receiving the draw amount. However, this 1 drawdown selection was prior to the remediation period performed by management. As such, it is included as a repeat finding, but as there were no exceptions in the remediation period, the finding is considered remediated. Cause During the audit period, the University experienced a transition in leadership within the Office of Research Administration. As part of this transition, the Associate Vice President for Research Administration was responsible for reviewing and approving drawdown requests, which was overlooked in certain instances. Effect The University processed drawdowns prior to supervisory approval. Questioned Costs None. Repeat Finding Yes Recommendation We recommend management revisit existing internal control procedures to ensure requested reimbursements are approved prior to the request

Show full finding ▾
Full finding narrative

Criteria In accordance with 2 CFR 200.302 (b)(3), the recipient must maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition We selected 25 drawdowns across all agencies for testing. Of these 25, 1 drawdown selection was approved 1 day after the drawdown request was submitted, but prior to receiving the draw amount. However, this 1 drawdown selection was prior to the remediation period performed by management. As such, it is included as a repeat finding, but as there were no exceptions in the remediation period, the finding is considered remediated. Cause During the audit period, the University experienced a transition in leadership within the Office of Research Administration. As part of this transition, the Associate Vice President for Research Administration was responsible for reviewing and approving drawdown requests, which was overlooked in certain instances. Effect The University processed drawdowns prior to supervisory approval. Questioned Costs None. Repeat Finding Yes Recommendation We recommend management revisit existing internal control procedures to ensure requested reimbursements are approved prior to the request

Corrective Action Plan

The University acknowledges the audit finding and remains committed to maintaining compliance with the cash management requirements outlined in 2 CFR 200.302 (b)(3), which stipulates that recipients must maintain records that sufficiently identify Federal awards and ensure that drawdowns are properly supported and authorized prior to submission. During the audit period, at least one drawdown was approved, one day retroactively, after submission but prior to receipt of funds. This occurred prior to the remediation period. No exceptions were identified in the remediation period, and the finding is considered remediated. The instance arose during a leadership transition with the Office of Research Administration. Since that time, the entire drawdown process, review and approval has been clarified under new leadership, and additional oversight has been implemented to ensure approvals are documented prior to submission. As part of the drawdown process review, the University developed a standardized drawdown template, which streamlines how the Federal award expense information is gathered, compared to approve budgeted amounts and reviewed for approval. The template documents the preparer, the approver and the dates of both for the respective drawdown. The Office of Research Administration received training on the use of the template in January and February 2026 and implementation is planned for February 2026. Primary responsibility for implementing the correction action plan for this finding rests with Angela Tagliaferri, Assistant Vice President of Post-Award Services and Financial Compliance, 216-368-6269.

Prior Finding References

2024-003

About Cash Management →
2025-002
Procurement & Suspension/Debarment
REPEATOTHER MATTERS

Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 6 of 25 samples were in excess of the University’s simplified acquisition threshold ($50,000 per the policy through 3/31/2025 and $250,000 per the policy starting 4/1/2025). Of the 6 that were in excess of the simplified acquisition threshold noted, only the 4 selections that were dated prior to 3/31/2025 did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). As such, this is included as a repeat finding, but as there were no exceptions in the remediation period, the finding is considered remediated. Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Repeat Finding Yes Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis.

Show full finding ▾
Full finding narrative

Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 6 of 25 samples were in excess of the University’s simplified acquisition threshold ($50,000 per the policy through 3/31/2025 and $250,000 per the policy starting 4/1/2025). Of the 6 that were in excess of the simplified acquisition threshold noted, only the 4 selections that were dated prior to 3/31/2025 did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). As such, this is included as a repeat finding, but as there were no exceptions in the remediation period, the finding is considered remediated. Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Repeat Finding Yes Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis.

Corrective Action Plan

The University acknowledges the audit finding and is committed to ensuring compliance with the procurement requirements outlined in 2 CFR 200.324 (a), which mandates that recipients perform a cost or price analysis for every procurement transaction exceeding the simplified acquisition threshold. During the audit period, it was identified that 4 sampled transactions exceeding the University’s simplified acquisition threshold of $50,000 lacked documented evidence of an independent cost or price analysis prior to March 31, 2025. In April 2025, the University remediated this policy and procedure. No exceptions were identified during the remediation period, and the finding is considered remediated. In April 2025, to address this finding and strengthen compliance, the University initiated the following corrective actions. First, the University worked with leadership to update its procurement policy to increase the simplified acquisition threshold to $250,000, aligning with federal guidelines. This change ensures that the University’s procurement processes are more consistent with federal standards. Second, a new requirement was implemented, mandating that a price analysis form be completed and retained for each procurement transaction exceeding the simplified acquisition threshold. This form documents the University’s independent price analysis. Third, the University provided targeted training to procurement staff and relevant stakeholders to ensure understanding and adherence to the updated policy and the new price analysis requirement. The training emphasized the importance of maintaining contemporaneous documentation in procurement files. Finally, the University implemented enhanced internal controls to ensure that all procurement transactions exceeding the simplified acquisition threshold are reviewed and approved by designated leadership, with documented evidence of a price analysis retained in the procurement files. Primary responsibility for implementing and monitoring this corrective action plan rests with Beth Connelly, Senior Director of Procurement Operations, 216-368-6332.

Prior Finding References

2024-004

About Procurement and Suspension and Debarment →
2025-002
Procurement & Suspension/Debarment
REPEATOTHER MATTERS

Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 6 of 25 samples were in excess of the University’s simplified acquisition threshold ($50,000 per the policy through 3/31/2025 and $250,000 per the policy starting 4/1/2025). Of the 6 that were in excess of the simplified acquisition threshold noted, only the 4 selections that were dated prior to 3/31/2025 did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). As such, this is included as a repeat finding, but as there were no exceptions in the remediation period, the finding is considered remediated. Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Repeat Finding Yes Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis.

Show full finding ▾
Full finding narrative

Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 6 of 25 samples were in excess of the University’s simplified acquisition threshold ($50,000 per the policy through 3/31/2025 and $250,000 per the policy starting 4/1/2025). Of the 6 that were in excess of the simplified acquisition threshold noted, only the 4 selections that were dated prior to 3/31/2025 did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). As such, this is included as a repeat finding, but as there were no exceptions in the remediation period, the finding is considered remediated. Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Repeat Finding Yes Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis.

Corrective Action Plan

The University acknowledges the audit finding and is committed to ensuring compliance with the procurement requirements outlined in 2 CFR 200.324 (a), which mandates that recipients perform a cost or price analysis for every procurement transaction exceeding the simplified acquisition threshold. During the audit period, it was identified that 4 sampled transactions exceeding the University’s simplified acquisition threshold of $50,000 lacked documented evidence of an independent cost or price analysis prior to March 31, 2025. In April 2025, the University remediated this policy and procedure. No exceptions were identified during the remediation period, and the finding is considered remediated. In April 2025, to address this finding and strengthen compliance, the University initiated the following corrective actions. First, the University worked with leadership to update its procurement policy to increase the simplified acquisition threshold to $250,000, aligning with federal guidelines. This change ensures that the University’s procurement processes are more consistent with federal standards. Second, a new requirement was implemented, mandating that a price analysis form be completed and retained for each procurement transaction exceeding the simplified acquisition threshold. This form documents the University’s independent price analysis. Third, the University provided targeted training to procurement staff and relevant stakeholders to ensure understanding and adherence to the updated policy and the new price analysis requirement. The training emphasized the importance of maintaining contemporaneous documentation in procurement files. Finally, the University implemented enhanced internal controls to ensure that all procurement transactions exceeding the simplified acquisition threshold are reviewed and approved by designated leadership, with documented evidence of a price analysis retained in the procurement files. Primary responsibility for implementing and monitoring this corrective action plan rests with Beth Connelly, Senior Director of Procurement Operations, 216-368-6332.

Prior Finding References

2024-004

About Procurement and Suspension and Debarment →

FY 2024-06-30

LOW-RISK AUDITEE$620,248,170 federal awards expended

FAC accepted this audit on March 14, 2025 — management decision was due September 14, 2025.

2024-001
Special Tests & Provisions
OTHER MATTERS

Criteria Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the NSLDS (OMB No. 1845-0035), (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Under the Direct Loan programs, schools must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by the Department of Education via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at every two months, but the minimum is twice a year. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis (Direct Loan, 34 CFR section 685.309). Condition Through our testing of enrollment reporting selections, we noted the following: • For 1 of 25 selections, we noted that the effective date of a change to graduated per the student file did not agree to the effective date of the change reported to NSLDS. • For 2 of 25 selections, we noted that the students were reported as withdrawn to NSLDS when they should have been reported as graduated to NSLDS. Questioned Costs None. Cause The Office of the University’s Registrar uses the National Student Clearinghouse (“NSC”) as its servicer for enrollment reporting to the NSLDS. The conditions resulted from student records that were either missing from or mismatched during the process by which the Office of the University's Registrar provides NSC with degree information. The Office of the University's Registrar did not reconcile degree data sent to NSC against the student information system degree awarded data. Effect The effective administration of Title IV loans could be impacted when changes in students’ status are not reported timely and accurately. The accuracy of enrollment information is important as the student’s enrollment status determines eligibility for the in-school status, deferment, grace periods, and repayments, as well as the Government’s payment of interest subsidies. Recommendation We recommend management implement controls to identify inconsistencies in enrollment reporting information and resolve any inconsistencies in a timely manner. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.

Show full finding ▾
Full finding narrative

Criteria Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the NSLDS (OMB No. 1845-0035), (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Under the Direct Loan programs, schools must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by the Department of Education via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at every two months, but the minimum is twice a year. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis (Direct Loan, 34 CFR section 685.309). Condition Through our testing of enrollment reporting selections, we noted the following: • For 1 of 25 selections, we noted that the effective date of a change to graduated per the student file did not agree to the effective date of the change reported to NSLDS. • For 2 of 25 selections, we noted that the students were reported as withdrawn to NSLDS when they should have been reported as graduated to NSLDS. Questioned Costs None. Cause The Office of the University’s Registrar uses the National Student Clearinghouse (“NSC”) as its servicer for enrollment reporting to the NSLDS. The conditions resulted from student records that were either missing from or mismatched during the process by which the Office of the University's Registrar provides NSC with degree information. The Office of the University's Registrar did not reconcile degree data sent to NSC against the student information system degree awarded data. Effect The effective administration of Title IV loans could be impacted when changes in students’ status are not reported timely and accurately. The accuracy of enrollment information is important as the student’s enrollment status determines eligibility for the in-school status, deferment, grace periods, and repayments, as well as the Government’s payment of interest subsidies. Recommendation We recommend management implement controls to identify inconsistencies in enrollment reporting information and resolve any inconsistencies in a timely manner. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.

Corrective Action Plan

The University acknowledges and agrees with this audit finding. During the months of August and September 2024 (concurrent with PwC’s audit fieldwork), enrollment data was reviewed by the Office of the University Registrar in preparation for the Completers List reporting related to Gainful Employment/Financial Value Transparency requirements. During the Completers List reconciliation process, it was determined by the Office of the University Registrar that all August 2024 graduates needed to have their status dates updated. Those updates took place in early October 2024. The Office of the University Registrar will run a query shortly after each conferral date to compare all graduates using all three program-level match criteria (credential level, CIP, program length) at the time of graduation to data submitted to NSC during the last enrollment file. The Office of the University's Registrar will also compare degree data sent to NSC against the student information system degree awarded data. The Office of the University's Registrar will continue to ensure that all error reports are resolved in a timely manner according to NSC and NSLDS timing guidelines. These processes were initiated for December 2024 graduates. The Office of the University Registrar will complete these comparison processes within 30 days of each degree conferral date and will take immediate action to directly update NSC and NSLDS if any discrepancies are found. Primary responsibility for implementing the corrective action plan for this finding rests with Amy Hammett, University Registrar and Associate Vice Provost for Student Information Systems, 216-368-4310

About Special Tests and Provisions →
2024-002
Special Tests & Provisions
OTHER MATTERS

Criteria Under 34 CFR 688.165 (a), except in the case of a post-withdrawal disbursement made in accordance with 34 CFR 668.22(a)(5), if an institution credits a student ledger account with Direct Loan, Federal Perkins Loan, or TEACH Grant program funds, the institution must notify the student or parent of (i) The anticipated date and amount of the disbursement; (ii) The student's or parent's right to cancel all or a portion of that loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement and have the loan proceeds or TEACH Grant proceeds returned to the Secretary; and, (iii) The procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement. Condition Through our testing of a sample of 27 students, 24 of the students had loans and we noted for all 24 of the samples, that the deadline by which the student or parent was expected to notify the school that he or she wishes to cancel the loan disbursement was not explicitly provided for. Questioned Costs None. Cause The University sends out a standard template e-mail disbursement notification to each student receiving financial aid. The email identifies the date and amount of disbursement, the right to cancel all or a portion of a loan, and the procedures which the student or parent must notify the school to cancel. However, within the disbursement notification template, the deadline within which the student/parent must notify the University for cancellation of the loan was not explicitly mentioned. Effect Not having complete and accurate policies and procedures related to the timely cancellation of Title IV funds, could result in late cancellations of federal student financial aid funds to the Department of Education. Recommendation We recommend management update its template to ensure it aligns with the requirement noted. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.

Show full finding ▾
Full finding narrative

Criteria Under 34 CFR 688.165 (a), except in the case of a post-withdrawal disbursement made in accordance with 34 CFR 668.22(a)(5), if an institution credits a student ledger account with Direct Loan, Federal Perkins Loan, or TEACH Grant program funds, the institution must notify the student or parent of (i) The anticipated date and amount of the disbursement; (ii) The student's or parent's right to cancel all or a portion of that loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement and have the loan proceeds or TEACH Grant proceeds returned to the Secretary; and, (iii) The procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement. Condition Through our testing of a sample of 27 students, 24 of the students had loans and we noted for all 24 of the samples, that the deadline by which the student or parent was expected to notify the school that he or she wishes to cancel the loan disbursement was not explicitly provided for. Questioned Costs None. Cause The University sends out a standard template e-mail disbursement notification to each student receiving financial aid. The email identifies the date and amount of disbursement, the right to cancel all or a portion of a loan, and the procedures which the student or parent must notify the school to cancel. However, within the disbursement notification template, the deadline within which the student/parent must notify the University for cancellation of the loan was not explicitly mentioned. Effect Not having complete and accurate policies and procedures related to the timely cancellation of Title IV funds, could result in late cancellations of federal student financial aid funds to the Department of Education. Recommendation We recommend management update its template to ensure it aligns with the requirement noted. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.

Corrective Action Plan

The University acknowledges that the template used for the disbursement notification previously did not explicitly state the deadline for cancellation. The template has been revised as of November 2024 to include a separate section clearly outlining both the procedure and deadline for canceling Title IV funding. This revised template is already being used for disbursement notifications. Primary responsibility for implementing the correction action plan for this finding rests with Mike Collins, Director of University Financial Aid, 216-368-6579.

About Special Tests and Provisions →
2024-003
Cash Management
OTHER MATTERS

Criteria In accordance with 2 CFR 200.302 (b)(3), the recipient must maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition We selected 25 drawdowns across all agencies for testing. Of these 25, there was no evidence of supervisory review for 2 drawdown selections. Further, 1 drawdown selection was approved 1 day after the drawdown request was submitted. Cause During the audit period, the University experienced a transition in leadership within the Office of Research Administration. As part of this transition, the Associate Vice President for Research Administration was responsible for reviewing and approving drawdown requests, which was overlooked in certain instances. Effect The University processed drawdowns prior to supervisory approval. Questioned Costs None. Recommendation We recommend management revisit existing internal control procedures to ensure requested reimbursements are approved prior to the request Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.

Show full finding ▾
Full finding narrative

Criteria In accordance with 2 CFR 200.302 (b)(3), the recipient must maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition We selected 25 drawdowns across all agencies for testing. Of these 25, there was no evidence of supervisory review for 2 drawdown selections. Further, 1 drawdown selection was approved 1 day after the drawdown request was submitted. Cause During the audit period, the University experienced a transition in leadership within the Office of Research Administration. As part of this transition, the Associate Vice President for Research Administration was responsible for reviewing and approving drawdown requests, which was overlooked in certain instances. Effect The University processed drawdowns prior to supervisory approval. Questioned Costs None. Recommendation We recommend management revisit existing internal control procedures to ensure requested reimbursements are approved prior to the request Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.

Corrective Action Plan

The University acknowledges the audit finding and remains committed to maintaining compliance with the cash management requirements outlined in 2 CFR 200.302(b)(3), which stipulates that recipients must maintain records that sufficiently identify Federal awards and ensure that drawdowns are properly supported and authorized prior to submission. During the audit period, the University experienced a transition in leadership within the Office of Research Administration. As part of this transition, the Associate Vice President for Research Administration was responsible for reviewing and approving drawdown requests. However, due to staffing adjustments and process changes during this period, at least two drawdowns were processed without prior approval from the Associate Vice President. Additionally, at least one drawdown was approved retroactively after submission. To address these issues and strengthen compliance, the University has implemented several corrective actions. A new Assistant Vice President of Post-Award Services and Financial Compliance has been hired on January 8, 2024 to provide dedicated oversight and ensure adherence to compliance standards. Furthermore, the Executive Director of Cash Management, the Assistant Vice President of Post-Award Services and Financial Compliance, and the Associate Vice President of Research Administration have all received targeted training in May of 2024 to reinforce the requirement for supervisory approval prior to drawdown submission. The University has also conducted a comprehensive review of its cash management processes, implementing enhanced internal controls to ensure all drawdown requests are reviewed, verified, and approved by designated leadership before submission. Lastly, a formalized transition plan has been developed to ensure continuity and compliance during future changes in leadership if such events were to occur. These corrective actions underscore the University’s commitment to maintaining the accuracy and integrity of its financial management processes. While no questioned costs were identified, the steps outlined above will help ensure ongoing compliance with Federal cash management requirements. Primary responsibility for implementing the correction action plan for this finding rests with Angela Tagliaferri, Assistant Vice President of Post-Award Services and Financial Compliance, 216-368-6269.

About Cash Management →
2024-004
Procurement & Suspension/Debarment
OTHER MATTERS

Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.

Show full finding ▾
Full finding narrative

Criteria In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction. For example, the recipient or subrecipient should consider potential workforce impacts in their analysis if the procurement transaction will displace public sector employees. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. Condition In our testing, 10 of 25 samples were in excess of the University’s simplified acquisition threshold of $50,000. These 10 selections did not have evidence of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause Management’s current policy does not require an independent cost or price analysis to be documented as part of the procurement process for those items meeting the University’s simplified acquisition threshold. Effect The University could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None. Recommendation We recommend that the University update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the University’s simplified acquisition threshold is maintained consistently in the procurement files. Documentation should clearly outline the University’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.

Corrective Action Plan

The University acknowledges the audit finding and is committed to ensuring compliance with the procurement requirements outlined in 2 CFR 200.324(a), which mandates that recipients perform a cost or price analysis for every procurement transaction exceeding the simplified acquisition threshold. During the audit period, it was identified that 10 out of 25 sampled transactions exceeding the University’s simplified acquisition threshold of $50,000 lacked documented evidence of an independent cost or price analysis. This was due to the University’s existing policy not requiring such documentation for transactions meeting the simplified acquisition threshold. To address this finding and strengthen compliance, the University has initiated the following corrective actions. First, the University is working with leadership to update its procurement policy to increase the simplified acquisition threshold to $250,000, aligning with federal guidelines. This change will ensure that the University’s procurement processes are more consistent with federal standards. Second, a new requirement will be implemented, mandating that a cost or price analysis form be completed and retained for each procurement transaction exceeding the simplified acquisition threshold. This form will document the University’s independent cost or price analysis. Third, the University will provide targeted training to procurement staff and relevant stakeholders to ensure understanding and adherence to the updated policy and the new cost or price analysis requirement. This training will emphasize the importance of maintaining contemporaneous documentation in procurement files. Finally, the University will implement enhanced internal controls to ensure that all procurement transactions exceeding the simplified acquisition threshold are reviewed and approved by designated leadership, with documented evidence of cost or price analysis retained in the procurement files. The University anticipates having documentation and protocols finalized and implemented by April 2025. Once in place, all FY25 to date will be reviewed to ensure compliance with the updated policy. These corrective actions underscore the University’s commitment to maintaining the accuracy, integrity, and compliance of its procurement processes. While no questioned costs were identified, the steps outlined above will help ensure ongoing compliance with federal procurement requirements. Primary responsibility for implementing and monitoring this corrective action plan rests with Ashley Frantz, Chief Procurement Officer, 216-368-2595.

About Procurement and Suspension and Debarment →

FY 2022-06-30

LOW-RISK AUDITEE$550,656,165 federal awards expended

FAC accepted this audit on March 16, 2023 — management decision was due September 16, 2023.

2022-001
Cash Management
REPEATOTHER MATTERS

Finding 2022-001 ? Cash Management Cluster: Research and Development Cluster Grantors: National Cancer Institute and National Science Foundation Assistance Listing #?s and Titles: 93.397, Cancer Centers Support Grants and 47.049, Mathematical and Physical Sciences Award Names: Case GI SPORE, Case Comprehensive Cancer Support Grant, MRI: Acquisition of an SEM instrumented to conduct inoperando observations of materials performance under external stimuli Award Year and Number: 08/21/21-07/31/22 (CA150964), 04/01/21-03/31/22 (CA043703), 08/01/20-07/31/23 (DMR-2018167) Criteria In accordance with 2 CFR 200.305 (b), for non-Federal entities other than states, payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per 2 CFR 200.208, or when the non- Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition In testing compliance with the cash management compliance requirement in accordance with the OMB Compliance Supplement, specifically the reimbursement method, 40 individual expenditures were tested to compare the date Case Western Reserve University (the ?University?) paid the vendor to the date the University requested sponsor reimbursement. We noted 8 instances in which reimbursement was requested from the sponsor before the University paid the vendor, as shown in the chart below. Assistance Listing # Award Number Expenditure Amount Date of Payment to Vendor Date of Reimbursement Request to Sponsor Date of Reimbursement from Sponsor 93.397 CA150964 $356 8/30/2021 8/26/2021 8/26/2021 93.397 CA043703 $269 10/4/2021 9/27/2021 9/27/2021 93.397 CA150964 $245 1/5/2022 9/27/2021 9/27/2021 93.397 CA150964 $300 1/5/2022 10/25/2021 10/25/2021 93.397 CA150964 $364 11/2/2021 10/25/2021 10/25/2021 93.397 CA043703 $895 6/2/2022 5/25/2022 5/25/2022 47.049 DMR-2018167 $2,735 6/27/2022 6/17/2022 6/17/2022 47.049 DMR-2018167 $35,000 6/27/2022 6/17/2022 6/17/2022 Cause Management?s current process when requesting reimbursement to sponsors is to ensure that the expenditures are incurred, however, payment may occur at a later date. Effect The University requested and received Federal reimbursement prior to paying vendors for the selected expenses. This is a repeat finding, in the prior year two exceptions were noted related to this finding. Questioned Costs None as reimbursement was requested for allowable costs. Recommendation The University should revisit existing internal control procedures to ensure requested reimbursements are received in compliance with Federal reimbursement requirements in the Compliance Supplement. 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 prior audit findings and status.

Show full finding ▾
Full finding narrative

Finding 2022-001 ? Cash Management Cluster: Research and Development Cluster Grantors: National Cancer Institute and National Science Foundation Assistance Listing #?s and Titles: 93.397, Cancer Centers Support Grants and 47.049, Mathematical and Physical Sciences Award Names: Case GI SPORE, Case Comprehensive Cancer Support Grant, MRI: Acquisition of an SEM instrumented to conduct inoperando observations of materials performance under external stimuli Award Year and Number: 08/21/21-07/31/22 (CA150964), 04/01/21-03/31/22 (CA043703), 08/01/20-07/31/23 (DMR-2018167) Criteria In accordance with 2 CFR 200.305 (b), for non-Federal entities other than states, payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per 2 CFR 200.208, or when the non- Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition In testing compliance with the cash management compliance requirement in accordance with the OMB Compliance Supplement, specifically the reimbursement method, 40 individual expenditures were tested to compare the date Case Western Reserve University (the ?University?) paid the vendor to the date the University requested sponsor reimbursement. We noted 8 instances in which reimbursement was requested from the sponsor before the University paid the vendor, as shown in the chart below. Assistance Listing # Award Number Expenditure Amount Date of Payment to Vendor Date of Reimbursement Request to Sponsor Date of Reimbursement from Sponsor 93.397 CA150964 $356 8/30/2021 8/26/2021 8/26/2021 93.397 CA043703 $269 10/4/2021 9/27/2021 9/27/2021 93.397 CA150964 $245 1/5/2022 9/27/2021 9/27/2021 93.397 CA150964 $300 1/5/2022 10/25/2021 10/25/2021 93.397 CA150964 $364 11/2/2021 10/25/2021 10/25/2021 93.397 CA043703 $895 6/2/2022 5/25/2022 5/25/2022 47.049 DMR-2018167 $2,735 6/27/2022 6/17/2022 6/17/2022 47.049 DMR-2018167 $35,000 6/27/2022 6/17/2022 6/17/2022 Cause Management?s current process when requesting reimbursement to sponsors is to ensure that the expenditures are incurred, however, payment may occur at a later date. Effect The University requested and received Federal reimbursement prior to paying vendors for the selected expenses. This is a repeat finding, in the prior year two exceptions were noted related to this finding. Questioned Costs None as reimbursement was requested for allowable costs. Recommendation The University should revisit existing internal control procedures to ensure requested reimbursements are received in compliance with Federal reimbursement requirements in the Compliance Supplement. 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 prior audit findings and status.

Corrective Action Plan

Management?s View and Corrective Action Plan Finding 2022-001 ? Cash Management Cluster: Research and Development Cluster Grantor: National Cancer Institute and National Science Foundation Assistance Listing #: 93.397, Cancer Centers Support Grants and 47.049, Mathematical and Physical Sciences Title: Case GI SPORE, Case Comprehensive Cancer Support Grant, MRI: Acquisition of an SEM instrumented to conduct in-operando observations of materials performance under external stimuli Award Year and Number: 08/21/21-07/31/22 (CA150964), 04/01/21-03/31/22 (CA043703), 08/01/20-07/31/23 (DMR-2018167) The University believes it is in compliance and currently follows regulations pertinent to cash management in 2 CFR Part 200.305(b) (Uniform Guidance) which requires "payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity." As such, organizations are to minimize the time difference between vendor payment and requesting reimbursement from the sponsoring agencies. We acknowledge that there are discrepancies in the interpretation of the Office of Management and Budget (0MB) cash management compliance requirements and the Uniform Guidance Part 200.305(b). In October 2017, the Council on Governmental Relations (COGR) sent a letter to the Office of Federal Financial Management (OFFM) expressing concerns that the cash management requirement language in the 2017 Compliance Supplement was not aligned with the requirements for cash management included in the Uniform Guidance Part 200.305(b). COGR's stance is for the Compliance Supplement to be updated to correspond with the cash management requirements as written in the Uniform Guidance Part 200.305(b). In August 2021, COGR sent a follow-up letter to OFFM regarding the 2021 Compliance Supplement emphasizing the inconsistency has yet to be addressed or resolved and most recently followed-up again in June 2022. In September 2022, The Office of Research Administration (ORA) sent a letter in support of COGR's June 2022 Comment Letter and followed up in November 2022 as well, with no response. The Office of Research Administration is sincerely devoted to ensuring institutional compliance with Uniform Guidance and the Compliance Supplement. It is important to note that these exceptions pertain to accounts payable transactions only. ORA will be cognizant of OMB's current interpretation of the Cash Management requirements and will continue to monitor for additional guidance regarding discrepancies in the Compliance Supplement. Primary responsibility for implementing this corrective action plan for this finding rests with Diane Domanovics, Assistant Vice President for Sponsored Projects. Sincerely, Joan Schenkel Associate Vice President for Research

Prior Finding References

2021-001

About Cash Management →

FY 2021-06-30

LOW-RISK AUDITEE$516,952,508 federal awards expended

FAC accepted this audit on June 16, 2022 — management decision was due December 16, 2022.

2021-001
Cash Management
OTHER MATTERS

Finding 2021-001 ? Cash ManagementGrantor: National Institutes of Health and Centers for Disease Control and PreventionProgram: Research and Development ClusterAssistance Listing #: 93.887 and 93.283Title: Myocardial Fibrosis and Development of New DiagnosticAward Year: 07/01/2020 ? 06/30/2021Award Number: HL141846 and 1NU38CK000480CriteriaIn accordance with 2 CFR 200.305 (b)(3), reimbursement is the preferred method when the requirementsin paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per 2 CFR200.208, or when the non-Federal entity requests payment by reimbursement. Per the OMB ComplianceSupplement, the non-Federal entity must disburse funds for program purposes before requesting paymentfrom the Federal awarding agency or pass-through entity.ConditionIn testing compliance with the cash management compliance requirement in accordance with the OMBCompliance Supplement, specifically the reimbursement method, 25 individual expenditures were testedto compare the date Case Western Reserve University (the ?University?) paid the vendor to the date theUniversity requested sponsor reimbursement. We noted 2 instances in which reimbursement wasrequested from the sponsor before the University paid the vendor, as shown in the chart below.AssistanceListing #Award Number ExpenditureAmountDate ofPayment toVendorDate ofReimbursementRequest to SponsorDate ofReimbursementfrom Sponsor93.887 HL141846 $3,574 12/10/2020 10/26/2020 10/26/202093.283 1NU38CK000480 $163 7/12/2021 6/24/2021 6/24/2021CauseManagement?s current process when requesting reimbursement to sponsors is to ensure that theexpenditures are incurred, however, payment may occur at a later date.EffectThe University requested and received Federal reimbursement prior to paying vendors for the selectedexpenses.Questioned CostsNone as reimbursement was requested for allowable costs.RecommendationCase Western Reserve University should revisit existing internal control procedures to ensure requestedreimbursements are received in compliance with Federal reimbursement requirements in the ComplianceSupplement.Management?s Views and Corrective Action PlanManagement?s views and corrective action plan is included at the end of this report.

Show full finding ▾
Full finding narrative

Finding 2021-001 ? Cash ManagementGrantor: National Institutes of Health and Centers for Disease Control and PreventionProgram: Research and Development ClusterAssistance Listing #: 93.887 and 93.283Title: Myocardial Fibrosis and Development of New DiagnosticAward Year: 07/01/2020 ? 06/30/2021Award Number: HL141846 and 1NU38CK000480CriteriaIn accordance with 2 CFR 200.305 (b)(3), reimbursement is the preferred method when the requirementsin paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per 2 CFR200.208, or when the non-Federal entity requests payment by reimbursement. Per the OMB ComplianceSupplement, the non-Federal entity must disburse funds for program purposes before requesting paymentfrom the Federal awarding agency or pass-through entity.ConditionIn testing compliance with the cash management compliance requirement in accordance with the OMBCompliance Supplement, specifically the reimbursement method, 25 individual expenditures were testedto compare the date Case Western Reserve University (the ?University?) paid the vendor to the date theUniversity requested sponsor reimbursement. We noted 2 instances in which reimbursement wasrequested from the sponsor before the University paid the vendor, as shown in the chart below.AssistanceListing #Award Number ExpenditureAmountDate ofPayment toVendorDate ofReimbursementRequest to SponsorDate ofReimbursementfrom Sponsor93.887 HL141846 $3,574 12/10/2020 10/26/2020 10/26/202093.283 1NU38CK000480 $163 7/12/2021 6/24/2021 6/24/2021CauseManagement?s current process when requesting reimbursement to sponsors is to ensure that theexpenditures are incurred, however, payment may occur at a later date.EffectThe University requested and received Federal reimbursement prior to paying vendors for the selectedexpenses.Questioned CostsNone as reimbursement was requested for allowable costs.RecommendationCase Western Reserve University should revisit existing internal control procedures to ensure requestedreimbursements are received in compliance with Federal reimbursement requirements in the ComplianceSupplement.Management?s Views and Corrective Action PlanManagement?s views and corrective action plan is included at the end of this report.

Corrective Action Plan

Management?s View and Corrective Action PlanFinding 2021-001 ? Cash ManagementGrantor: National Institutes of Health and Centers for Disease Control and PreventionProgram: Research and Development ClusterAssistance Listing #: 93.887 and 93.283Title: Myocardial Fibrosis and Development of New DiagnosticAward Year: 07/01/2020 ? 06/30/2021Award Number: HL141846 and 1NU38CK000480The University believes it is in compliance and currently follows regulations pertinent to cashmanagement in 2 CFR Part 200.305(b) (Uniform Guidance) which requires ?payments methods mustminimize the time elapsing between the transfer of funds from the United States Treasury or thepass-through entity and the disbursement by the non-Federal entity.? As such, organizations are tominimize the time difference between vendor payment and requesting reimbursement from thesponsoring agencies.We acknowledge that there are discrepancies in the interpretation of the Office of Management andBudget (OMB) cash management compliance requirements and the Uniform Guidance Part 200.305(b).In October 2017, the Council on Governmental Relations (COGR) sent a letter to the Office of FederalFinancial Management (OFFM) expressing concerns that the cash management requirement language inthe 2017 Compliance Supplement was not aligned with the requirements for cash management includedin the Uniform Guidance Part 200.305(b). COGR?s stance is for the Compliance Supplement to beupdated to correspond with the cash management requirements as written in the Uniform Guidance Part200.305(b). Most recently, in August 2021, COGR sent a follow-up letter to OFFM regarding the 2021Compliance Supplement emphasizing the inconsistency has yet to be addressed or resolved.The Office of Research Administration (ORA) is sincerely devoted to ensuring institutional compliancewith Uniform Guidance and the Compliance Supplement. It is important to note that these exceptionspertain to accounts payable transactions only. ORA will be cognizant of OMB's current interpretation ofthe Cash Management requirements and will continue to monitor for additional guidance regardingdiscrepancies in the Compliance Supplement.Primary responsibility for implementing this corrective action plan for this finding rests with DianeDomanovics, Assistant Vice President for Sponsored Projects.Sincerely,Diane DomanovicsAssistant Vice President for Sponsored Projects

About Cash Management →

FY 2018-06-30

LOW-RISK AUDITEE$525,214,572 federal awards expended

FAC accepted this audit on March 27, 2019 — management decision was due September 27, 2019.

2018-001
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2018-002
Special Tests & Provisions
OTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Special Tests and Provisions →
2018-003
Special Tests & Provisions
QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Special Tests and Provisions →

FY 2017-06-30

LOW-RISK AUDITEE$488,687,506 federal awards expended

FAC accepted this audit on March 28, 2018 — management decision was due September 28, 2018.

2017-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Special Tests and Provisions →
2017-002
Eligibility
QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Eligibility →
2017-003
Special Tests & Provisions
OTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Special Tests and Provisions →
2017-004
Special Tests & Provisions
OTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Special Tests and Provisions →

Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.

Are you this organization?

Track your findings and corrective action plans across audit cycles.

Start tracking findings →

Do you fund this organization?

Monitor subrecipient audit findings and filing records.

Start monitoring →

Product

Resources

Legal

Single Audit Intelligence is an independent tool powered by Federal Audit Clearinghouse data. Not affiliated with GSA, OMB, or any federal agency.

© 2026 Single Audit Intelligence. All data is public domain.