EIN: 380298770
UEI: LXS1B8J23AJ7
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 31, 2024. 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 July 31, 2024 (757 days ago).
What is a management decision? →Assistance Listing Number, Federal Agency, and Program Name - 12.300, Office of Naval Research, Research and Development Cluster Federal Award Identification Number and Year - N0001 19 S F006 Finding Type - Significant deficiency Repeat Finding - Yes 2020 001 Criteria - Per 2 CFR 430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. The records must reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100 percent of compensated activities. Condition - The budgeting and billing methods used did not impose limitations, as required by the terms and provisions of the grant agreement. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - Originally identified in 2020, the Organization initially charged amounts to the grant that exceeded actual compensation costs. This was resolved in late 2021, and, as a result, the Organization did not submit reimbursement requests to the Office of Naval Research until a revised budget was approved and correct billing practices put in place. Cause and Effect - The Organization did not have the internal controls in place to identify this error and was unable to correct it until a third party consultant was hired to correct the error. Recommendation - Management should implement controls to ensure expenditures charged to the grant accurately reflect the work performed and comply with terms and provisions of the grant agreement. Views of Responsible Officials and Corrective Action Plan - The Organization acknowledges this finding. Billing for 2021 and 2022 was held once the error was discovered to avoid exacerbating the problem. The amount that was overbilled was returned to the agency by reducing the amount of reimbursement requests for 2021. All of the revised billings and reimbursement were completed in November 2022. Management has also implemented controls to ensure expenditures charged to the grant accurately reflect the work performed and comply with terms and provisions of the grant agreement and appointed outside consultants to ensure appropriate billing and indirect cost rate calculations.
Show full finding ▾Hide full finding ▴Assistance Listing Number, Federal Agency, and Program Name - 12.300, Office of Naval Research, Research and Development Cluster Federal Award Identification Number and Year - N0001 19 S F006 Finding Type - Significant deficiency Repeat Finding - Yes 2020 001 Criteria - Per 2 CFR 430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. The records must reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100 percent of compensated activities. Condition - The budgeting and billing methods used did not impose limitations, as required by the terms and provisions of the grant agreement. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - Originally identified in 2020, the Organization initially charged amounts to the grant that exceeded actual compensation costs. This was resolved in late 2021, and, as a result, the Organization did not submit reimbursement requests to the Office of Naval Research until a revised budget was approved and correct billing practices put in place. Cause and Effect - The Organization did not have the internal controls in place to identify this error and was unable to correct it until a third party consultant was hired to correct the error. Recommendation - Management should implement controls to ensure expenditures charged to the grant accurately reflect the work performed and comply with terms and provisions of the grant agreement. Views of Responsible Officials and Corrective Action Plan - The Organization acknowledges this finding. Billing for 2021 and 2022 was held once the error was discovered to avoid exacerbating the problem. The amount that was overbilled was returned to the agency by reducing the amount of reimbursement requests for 2021. All of the revised billings and reimbursement were completed in November 2022. Management has also implemented controls to ensure expenditures charged to the grant accurately reflect the work performed and comply with terms and provisions of the grant agreement and appointed outside consultants to ensure appropriate billing and indirect cost rate calculations.
Statement of Condition - The budgeting and billing methods used did not impose limitations, as required by the terms and provisions of the grant agreement. Planned Corrective Action Plan - Management has also implemented controls to ensure expenditures charged to the grant accurately reflect the work performed and comply with terms and provisions of the grant agreement and appointed outside consultants to ensure appropriate billing and indirect cost rate calculations. Contact person responsible for corrective action: Craig Connop, CFO Completion Date: November 15, 2023
2020-001
FAC accepted this audit on February 15, 2023 — management decision was due August 15, 2023.
ALN, Federal Agency, and Program Name 12.300, Office of Naval Research, Research and Development Cluster Federal Award Identification Number and Year N00014 19 S F006 Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria Per 2 CFR 430, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. The records must reasonably reflect the total activity for which the employee is compensated by the non Federal entity, not exceeding 100% of compensated activities. Condition The budgeting and billing methods used did not impose limitations, as required by the terms and provisions of the grant agreement. Questioned Costs None Identification of How Questioned Costs Were Computed Not applicable Context The Organization charged compensation costs of $1,557,321 to the grant for the year ended December 31, 2020. These costs were computed by applying a premium billing rate to the employee hours charged to the grant. Management revised its billings for the year ended December 31, 2020 to ensure compensation expenses accurately reflected actual expenditures for the grant. Costs charged to the grant in excess of actual costs totaled $521,612 and have been excluded from the schedule of expenditures of federal awards (SEFA) as of December 31, 2020. Cause and Effect Amounts submitted to the Office of Naval Research for reimbursement included salary and wage expenditures based on market billing rates, rather than actual costs of payroll expenditures. As a result, the Organization charged amounts to the grant that exceeded actual compensation costs. Recommendation We recommend returning the amount of questioned costs to the agency by reducing the amount of future reimbursement requests. Management should also implement controls to ensure expenditures charged to the grant accurately reflect the work performed and comply with terms and provisions of the grant agreement. Views of Responsible Officials and Corrective Action Plan The Organization acknowledges this finding. Billing for 2021 and 2022 was held once the error was discovered to avoid exacerbating the problem. The amount that was overbilled was returned to the agency by reducing the amount of reimbursement requests for 2021. All of the revised billings and reimbursement were completed in November 2022. Management has also implemented controls to ensure expenditures charged to the grant accurately reflect the work performed and comply with terms and provisions of the grant agreement and appointed outside consultants to ensure appropriate billing and indirect cost rate calculations.
Show full finding ▾Hide full finding ▴ALN, Federal Agency, and Program Name 12.300, Office of Naval Research, Research and Development Cluster Federal Award Identification Number and Year N00014 19 S F006 Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria Per 2 CFR 430, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. The records must reasonably reflect the total activity for which the employee is compensated by the non Federal entity, not exceeding 100% of compensated activities. Condition The budgeting and billing methods used did not impose limitations, as required by the terms and provisions of the grant agreement. Questioned Costs None Identification of How Questioned Costs Were Computed Not applicable Context The Organization charged compensation costs of $1,557,321 to the grant for the year ended December 31, 2020. These costs were computed by applying a premium billing rate to the employee hours charged to the grant. Management revised its billings for the year ended December 31, 2020 to ensure compensation expenses accurately reflected actual expenditures for the grant. Costs charged to the grant in excess of actual costs totaled $521,612 and have been excluded from the schedule of expenditures of federal awards (SEFA) as of December 31, 2020. Cause and Effect Amounts submitted to the Office of Naval Research for reimbursement included salary and wage expenditures based on market billing rates, rather than actual costs of payroll expenditures. As a result, the Organization charged amounts to the grant that exceeded actual compensation costs. Recommendation We recommend returning the amount of questioned costs to the agency by reducing the amount of future reimbursement requests. Management should also implement controls to ensure expenditures charged to the grant accurately reflect the work performed and comply with terms and provisions of the grant agreement. Views of Responsible Officials and Corrective Action Plan The Organization acknowledges this finding. Billing for 2021 and 2022 was held once the error was discovered to avoid exacerbating the problem. The amount that was overbilled was returned to the agency by reducing the amount of reimbursement requests for 2021. All of the revised billings and reimbursement were completed in November 2022. Management has also implemented controls to ensure expenditures charged to the grant accurately reflect the work performed and comply with terms and provisions of the grant agreement and appointed outside consultants to ensure appropriate billing and indirect cost rate calculations.
Finding Number: 2020-001 Condition: The budgeting and billing methods used did not impose limitations, as required by the terms and provisions of the grant agreement. Planned Corrective Action: Billing for 2021 and 2022 was held once the error was discovered to avoid exacerbating the problem. The amount that was over-billed was returned to the agency, by reducing the amount of reimbursement requests for 2021. All of the revised billings and reimbursement were completed 11/18/2022. Management has also implemented controls to ensure expenditures charged to the grant accurately reflect the work performed and comply with terms and provisions of the grant agreement and appointed outside consultants (Capital Edge Consulting) to ensure appropriate billing and indirect cost rate calculations. Contact person responsible for corrective action: Craig Connop, CFO Completion Date:11/18/2022
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