EIN: 481108830
UEI: YXJGGNC5J269
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 22, 2023. 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 June 22, 2024 (795 days ago).
What is a management decision? →U.S. Department of Commerce Congressionally Identified Projects – 11.617 Award Number - 60NANB22D201 Criteria or Specific Requirement – Cash Management 2 CFR 200.305(b) of the compliance supplement requires organizations receiving federal funds to establish controls and procedures that would minimize the amount of time between drawdowns and disbursement of the funds. As required per the Department of Commerce Financial Assistance Standard Terms and Conditions, Section B, "Financial Requirements", paragraph .02.b1, advanced payments must be limited to immediate cash needs and must time advance payment requests so that Federal funds are on hand for a maximum of 30 calendar days before being disbursed by the non-Federal entity for allowable award costs. Condition – RI requested an advance payment in October 2022 for anticipated expenditures and did not expend all funding within the 30 day period. Questioned Costs – None noted. Context – We selected one drawdown for $1,000,000 out of three drawdowns totaling $3,000,000 during fiscal year 2023 for testing. During our testwork, we noted that a portion of the drawdown was not expended within the 30 day period following the receipt of the drawdown. The sample was not intended to be, and was not a statistically valid sample. Effect – RI did not comply with the 30 day period required for advanced payments. Cause – RI had issued purchase orders to vendors prior to advance payment request, but did not receive invoices from vendors for payment within the 30 day period and, as such, did not disburse funding. Identification as a Repeat Finding – Not applicable. Recommendation – We recommend RI only request advance payments up to the amount they are able to disburse within the required time in order to minimize the time elapsing between the receipt and disbursement of federal funds. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Show full finding ▾Hide full finding ▴U.S. Department of Commerce Congressionally Identified Projects – 11.617 Award Number - 60NANB22D201 Criteria or Specific Requirement – Cash Management 2 CFR 200.305(b) of the compliance supplement requires organizations receiving federal funds to establish controls and procedures that would minimize the amount of time between drawdowns and disbursement of the funds. As required per the Department of Commerce Financial Assistance Standard Terms and Conditions, Section B, "Financial Requirements", paragraph .02.b1, advanced payments must be limited to immediate cash needs and must time advance payment requests so that Federal funds are on hand for a maximum of 30 calendar days before being disbursed by the non-Federal entity for allowable award costs. Condition – RI requested an advance payment in October 2022 for anticipated expenditures and did not expend all funding within the 30 day period. Questioned Costs – None noted. Context – We selected one drawdown for $1,000,000 out of three drawdowns totaling $3,000,000 during fiscal year 2023 for testing. During our testwork, we noted that a portion of the drawdown was not expended within the 30 day period following the receipt of the drawdown. The sample was not intended to be, and was not a statistically valid sample. Effect – RI did not comply with the 30 day period required for advanced payments. Cause – RI had issued purchase orders to vendors prior to advance payment request, but did not receive invoices from vendors for payment within the 30 day period and, as such, did not disburse funding. Identification as a Repeat Finding – Not applicable. Recommendation – We recommend RI only request advance payments up to the amount they are able to disburse within the required time in order to minimize the time elapsing between the receipt and disbursement of federal funds. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Corrective Action Plan Finding Reference 2023-001 Personnel Responsible for Corrective Action: Matt Morgan, Assistant Director Sponsored Programs Administration Post-Award Anticipated Completion Date: November 1, 2023 Views of Responsible Officials and Planned Corrective Action: The RI concurs with the finding above and acknowledges that we drew down advance payments to cover encumbered costs rather than paid expenses, which resulted in retaining cash for more than 30 days. This approach was erroneous and did not account for the possibility of encumbrances remaining open for greater than 30 days. In response to the above issue, we have developed new processes to ensure our cash drawdowns align appropriately to reimburse expenses and prevent cash on hand: Rather than accept advance payments, we will use preferred method of reimbursement to draw down funds. Training for staff on cash management policy for Department of Commerce and Uniform Guidance Assistant Director for SPA Post-Award will review award setup and LOC draw terms to ensure no advance payments are being drawn down.
FAC accepted this audit on December 19, 2021 — management decision was due June 19, 2022.
2021-002 Information on the Federal Program - Research and Development Cluster, Multple Federal Grantors, Multiple Award Periods Criteria or Specific Requirement - Program costs must be paid by non-federal entity funds before submitting a payment request (2 CFR Section 200.305(b)(3)) (i.e., the non-federal entity must disburse funds for program purposes before requesting payment). Condition ? In February 2021, RI processed a duplicate draw relating to numerous research and development grants from the payment management system and did not detect or correct the error until August 2021. Questioned Costs ? The total amount of the duplicate draw was $1,039,895 and encompassed the following awards: Federal Federal Award Federal Federal Award Federal Federal Award Assistance Identification Assistance Identification Assistance Identification Listing Number Amount Listing Number Amount Listing Number Amount 93.110 T73MC06623 $ 1 75 93.847 NIH R01DK102142 $ 1 6,082 93.859 2P20GM103418 20 $ 6 8,115 93.113 R01ES029203 6 ,816 93.847 K23DK109294 5 0 93.859 R01GM128241 679 93.113 1R21ES028957-01A1 1 2 93.847 R01DK098414 5 ,276 93.859 R01GM115340 933 93.121 R01DE026955 3 05 93.847 DK099611-06 8 ,522 93.859 5R01GM077336-11 12,694 93.121 R01DE026172 1 2,120 93.847 5K01DK113048-02 5 22 93.859 5P30GM12273104 86 93.134 U1333878 1 18,498 93.847 K01DK112967 3 ,276 93.865 5T32HD057850-12 412 93.226 1R01HS026134-01A1 1 53 93.847 1R01DK123590-01 1 1 93.865 R01HD020676 15,906 93.273 U01AA024733 1 ,340 93.847 5R01DK108433-05 9 78 93.865 1K99HD099269-01 121 93.273 1R21AA026904-01 5 60 93.847 1R01DK122212-02 4 ,101 93.865 R01HD083292 3 93.273 5R01AA027586-03 4 ,760 93.847 R01DK121497 4 6 93.865 R01HD094545 5,406 93.273 5R01AA012863-18 6 ,701 93.847 5R01DK113111-05 5 1,316 93.865 R21HD099364 6,478 93.279 5 R01 DA042715-05 1 6,613 93.847 5R01DK115727-02 2 ,458 93.865 R01HD101319 57,040 93.279 R01DA046576 5 ,990 93.847 1R01DK119131-01A1 6 ,992 93.866 R01AG052954 5,772 93.310 UL1TR002366 4 43,642 93.853 5R01NS030853-27 2 ,520 93.866 1R21AG066488 24 93.350 KL2TR002367 6 ,332 93.853 5R01NS043314-15 6 19 93.866 R24AG063724 9,636 93.350 TL1TR002368 1 7,656 93.855 1R01AI121073-01A1 1 ,125 93.866 1R01AG060050-01A1 12,158 93.350 5UL1TR002366-04 4 0,044 93.855 R21Al142028 1 ,664 93.866 R01AG062548 50 93.361 R01NR16255 01A1 8 0 93.855 R21AI144883 5 30 93.866 R01AG060157 1,736 93.393 R01CA185322 5 51 93.855 1R01AI150877-01 1 ,316 93.866 R01AG061194 437 93.393 R01CA201309 3 6 93.855 R21AI151542 3 47 93.866 R01AG060733 1,698 93.395 R37CA218118 1 ,991 93.855 1R21AI144698-01 1 3,733 93.866 R01AG064227 3,538 93.396 1R01CA227838-01A1 7 ,502 93.855 5R01AI147276-03 4 ,457 93.866 R21AG061548 12,819 93.397 P30CA168524 5 40 93.855 R21AI144624 3 ,611 93.866 F30AG058397 120 93.838 R01HL139365 1 ,944 93.859 4R01GM029764-33 7 8 93.866 R61AG068483 23 93.982 1H79FG000177-01 2 0 $ 1 ,039,895 Context ? During the year-end closing procedures, management identified a duplicate draw that occurred during February 2021. The error was corrected in the payment management system in August 2021 and disclosed to us during the audit process. Effect ? Federal funds were improperly held by RI for approximately seven months. Cause ? After the original draw occurred, the payment was not posted against the invoices and costs included in the request. As a result, the same invoices and costs were included again in the immediately following draw down which resulted in the overpayment. Recommendation ? We recommend that management review the current processes and internal controls for cash management and manke necessary changes to ensure federal draws are processed accurately and reconciled timely. Views of Responsible Officials and Planned Corrective Actions ? Management agrees with the stated finding and has implemented a corrective action plan.
Show full finding ▾Hide full finding ▴2021-002 Information on the Federal Program - Research and Development Cluster, Multple Federal Grantors, Multiple Award Periods Criteria or Specific Requirement - Program costs must be paid by non-federal entity funds before submitting a payment request (2 CFR Section 200.305(b)(3)) (i.e., the non-federal entity must disburse funds for program purposes before requesting payment). Condition ? In February 2021, RI processed a duplicate draw relating to numerous research and development grants from the payment management system and did not detect or correct the error until August 2021. Questioned Costs ? The total amount of the duplicate draw was $1,039,895 and encompassed the following awards: Federal Federal Award Federal Federal Award Federal Federal Award Assistance Identification Assistance Identification Assistance Identification Listing Number Amount Listing Number Amount Listing Number Amount 93.110 T73MC06623 $ 1 75 93.847 NIH R01DK102142 $ 1 6,082 93.859 2P20GM103418 20 $ 6 8,115 93.113 R01ES029203 6 ,816 93.847 K23DK109294 5 0 93.859 R01GM128241 679 93.113 1R21ES028957-01A1 1 2 93.847 R01DK098414 5 ,276 93.859 R01GM115340 933 93.121 R01DE026955 3 05 93.847 DK099611-06 8 ,522 93.859 5R01GM077336-11 12,694 93.121 R01DE026172 1 2,120 93.847 5K01DK113048-02 5 22 93.859 5P30GM12273104 86 93.134 U1333878 1 18,498 93.847 K01DK112967 3 ,276 93.865 5T32HD057850-12 412 93.226 1R01HS026134-01A1 1 53 93.847 1R01DK123590-01 1 1 93.865 R01HD020676 15,906 93.273 U01AA024733 1 ,340 93.847 5R01DK108433-05 9 78 93.865 1K99HD099269-01 121 93.273 1R21AA026904-01 5 60 93.847 1R01DK122212-02 4 ,101 93.865 R01HD083292 3 93.273 5R01AA027586-03 4 ,760 93.847 R01DK121497 4 6 93.865 R01HD094545 5,406 93.273 5R01AA012863-18 6 ,701 93.847 5R01DK113111-05 5 1,316 93.865 R21HD099364 6,478 93.279 5 R01 DA042715-05 1 6,613 93.847 5R01DK115727-02 2 ,458 93.865 R01HD101319 57,040 93.279 R01DA046576 5 ,990 93.847 1R01DK119131-01A1 6 ,992 93.866 R01AG052954 5,772 93.310 UL1TR002366 4 43,642 93.853 5R01NS030853-27 2 ,520 93.866 1R21AG066488 24 93.350 KL2TR002367 6 ,332 93.853 5R01NS043314-15 6 19 93.866 R24AG063724 9,636 93.350 TL1TR002368 1 7,656 93.855 1R01AI121073-01A1 1 ,125 93.866 1R01AG060050-01A1 12,158 93.350 5UL1TR002366-04 4 0,044 93.855 R21Al142028 1 ,664 93.866 R01AG062548 50 93.361 R01NR16255 01A1 8 0 93.855 R21AI144883 5 30 93.866 R01AG060157 1,736 93.393 R01CA185322 5 51 93.855 1R01AI150877-01 1 ,316 93.866 R01AG061194 437 93.393 R01CA201309 3 6 93.855 R21AI151542 3 47 93.866 R01AG060733 1,698 93.395 R37CA218118 1 ,991 93.855 1R21AI144698-01 1 3,733 93.866 R01AG064227 3,538 93.396 1R01CA227838-01A1 7 ,502 93.855 5R01AI147276-03 4 ,457 93.866 R21AG061548 12,819 93.397 P30CA168524 5 40 93.855 R21AI144624 3 ,611 93.866 F30AG058397 120 93.838 R01HL139365 1 ,944 93.859 4R01GM029764-33 7 8 93.866 R61AG068483 23 93.982 1H79FG000177-01 2 0 $ 1 ,039,895 Context ? During the year-end closing procedures, management identified a duplicate draw that occurred during February 2021. The error was corrected in the payment management system in August 2021 and disclosed to us during the audit process. Effect ? Federal funds were improperly held by RI for approximately seven months. Cause ? After the original draw occurred, the payment was not posted against the invoices and costs included in the request. As a result, the same invoices and costs were included again in the immediately following draw down which resulted in the overpayment. Recommendation ? We recommend that management review the current processes and internal controls for cash management and manke necessary changes to ensure federal draws are processed accurately and reconciled timely. Views of Responsible Officials and Planned Corrective Actions ? Management agrees with the stated finding and has implemented a corrective action plan.
2021-002 Personnel Responsible for Corrective Action: Paul Toler, Matt Woolley Anticipated Completion Date: 11/1/2021 Corrective Action Plan: The conditions noted above resulted in the duplicate draw not being identified in a timely manner. Duties have been segregated between the Controller and Accounting Manager to develop a preventative control such that a draw will not occur without being reflected in the RI?s general ledger. Also, the new processes noted previously are a detective control that will identify errors in a timely manner and result in immediate correction. The business process changes noted above have been implemented as of 11/1/2021.
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