CONSORTIUM OF UNIVERSITIES FOR THE ADVANCEMENT OF HYDROLOGICAL SCIENCE, INC.

EIN: 522326356

UEI: V7M9C3ZFCLS7

Data as of August 20, 2026

11
Audit Years
55
Total Findings
33
Repeat Findings

FY 2024-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on February 18, 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 August 18, 2026, which was (2 days ago).

What is a management decision? →
2024-001
Reporting
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation, U.S. Department of Commerce & National Aeronautics and Space Administration Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Integrative Activities, NOAA – Cooperative Institute & National Aeronautics and Space Administration AL No.: 47.050, 47.070, 47.083, 11.432 & 43.001 Federal Award Identification No. & Award Period: EAR-1849458 (05/21/2019 - 07/21/2026), EAR-2012893 (07/17/2020 – 07/22/2024), EAR-2244446 (03/01/2023 – 02/28/2026), EAR-2322510 (11/15/2023 – 10/31/2026), EAR-2121108 (10/01/2022 – 09/30/2024), OAC-2209833 (01/01/2023 – 12/31/2026), OAC-1835592 (01/01/2019 – 12/31/2024), OAC-1835818 (10/01/2018 – 09/30/2024), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026), OAC-2320979 (01/01/2024 – 12/31/2027), OAC-2410992 (09/01/2024 – 08/31/2026), OIA-1937099 (09/01/2020 – 08/31/2024), A22NWS4320003 (08/01/2022 – 07/25/2025, 08/01/2022 – 07/25/2025, 04/01/2023 – 03/31/2024, 06/01/2023 – 05/31/2024, 06/01/2023 – 05/31/2025, 06/01/2023 – 05/31/2026, 06/01/2023 – 05/31/2025, 04/01/2024 – 03/31/2026, 07/01/2024 – 06/30/2025, 07/01/2024 – 06/30/2026, 07/01/2024 – 06/30/2025) & 80NSSC22k0965 (04/22/2022 – 04/24/2025) Pass Through Entity: University of Alabama & Ohio State University MW2024-001 REPORTING - DCF Material Weakness Criteria 2 CFR Section 200.512(a) requires the reporting package and DCF to be submitted to the Federal Audit Clearinghouse the earlier of thirty calendar days after the reports are received from the auditor or nine months after the end of the audit period. Condition Due to the delay in financial close of CUAHSI’s books and records, a federal single audit for fiscal year 2024 was not performed in a timely manner and the DCF was not submitted by its due date of September 30, 2025. The UG requires the reporting package and DCF to be submitted to the Federal Audit Clearinghouse the earlier of 30 calendar days after the reports are received from the auditor (February 10, 2026) or nine months after CUAHSI’s year end (September 30, 2025).Cause & Context CUAHSI did not have effective controls in place to allow for a timely year-end closing. This caused significant auditor delays which resulted in CUAHSI’s inability to meet the filing requirements under the UG. Effect CUAHSI noncompliance could result in financial or programmatic consequences to CUAHSI. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2023-001. Recommendation Management should implement policies to ensure timely financial reporting and ensure the timely completion of an audit. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Finding Reference Number: MW2024-001 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: CUAHSI is behind on submitting an audit for fiscal year (FY) 2024. Management has made clearing this backlog its highest priority and the FY 2025 package will be filed on or before the deadline of September 30th, 2026. Recent upgrades to the accounting system, the hiring of inhouse finance staff, and revised closing procedures are designed to streamline and accelerate future audit preparation so that all subsequent audits are filed by the required deadlines. Name of Contact Person: • Maureen S. Ako, Director of Finance • Telephone: (339) 221-5400 • Email: msabino@cuahsi.org Projected Completion Date: 2026-09-30

Prior Finding References

2023-001

About Reporting →

FY 2023-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on November 20, 2025. 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 May 20, 2026, which was (92 days ago).

What is a management decision? →
2023-001
Reporting
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation, U.S. Department of Commerce & National Aeronautics and Space Administration Federal program title: Geosciences, Computer and Information Science and Engineering, Office of International Science and Engineering, NOAA – Cooperative Institute & National Aeronautics and Space Administration AL No.: 47.050, 47.070, 47.079, 11.432 & 43.001 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2023), EAR- 2244446 (03/01/2023 – 02/28/2026), OAC-2209833 (01/01/2023 – 12/31/2026), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2024), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026), OISE-1855654 (05/15/2019 – 12/31/2023), A22NWS4320003 (08/01/2022 – 07/25/2025, 08/01/2022 – 07/25/2025, 04/01/2023 – 03/31/2024, 06/01/2023 – 05/31/2024, 06/01/2023 – 05/31/2026, 06/01/2023 – 05/31/2025, 06/01/2023 – 05/31/2025) & 80NSSC22k0965 (06/01/2023 – 05/31/2026) Pass Through Entity: University of Alabama & Ohio State University MW2023-001 REPORTING - DCF Material Weakness Criteria 2 CFR Section 200.512(a) requires the reporting package and DCF to be submitted to the Federal Audit Clearinghouse the earlier of thirty calendar days after the reports are received from the auditor or nine months after the end of the audit period. Condition Due to the delay in financial close of CUAHSI’s books and records, a federal single audit for fiscal year 2023 was not performed in a timely manner and the DCF was not submitted by its due date of September 30, 2024. The UG requires the reporting package and DCF to be submitted to the Federal Audit Clearinghouse the earlier of 30 calendar days after the reports are received from the auditor (October 30, 2025) or nine months after CUAHSI’s year end (September 30, 2024). Cause & Context CUAHSI did not have effective controls in place to allow for a timely year-end closing. This caused significant auditor delays which resulted in CUAHSI’s inability to meet the filing requirements under the UG. Effect CUAHSI is not in compliance with 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2022-004. Recommendation Management should implement policies to ensure timely financial reporting and ensure the timely completion of an audit. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHS! impacting audit year 2023: NA Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI is behind on submitting an audit for fiscal year (FY) 2023. Management has made clearing this backlog its highest priority. The schedule is to complete and file the FY 2023 package by fall 2025 and the FY 2024 package shortly thereafter, at which point CUAHSI expects to return to on-time Federal Audit Clearinghouse filings. Recent upgrades to the accounting system, the hiring of in-house finance staff, and revised closing procedures are designed to streamline and accelerate future audit preparation so that all subsequent audits are filed by the required deadlines. Name of Contact Person: • Maureen S. Ako, Director of Finance • Telephone: (339) 221-5400 • Email: msabino@cuahsi.org Projected Completion Date: 2026-09-30

Prior Finding References

2022-004

About Reporting →
2023-002
Procurement & Suspension/Debarment
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation & U.S. Department of Commerce Federal program title: Geosciences, Computer and Information Science and Engineering, Office of International Science and Engineering & NOAA – Cooperative Institute AL No.: 47.050, 47.070, 47.079 & 11.432 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2023), EAR- 2244446 (03/01/2023 – 02/28/2026), OAC-2209833 (01/01/2023 – 12/31/2026), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2024), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026), OISE-1855654 (05/15/2019 – 12/31/2023) & A22NWS4320003 (08/01/2022 – 07/25/2025, 08/01/2022 – 07/25/2025, 04/01/2023 – 03/31/2024, 06/01/2023 – 05/31/2024, 06/01/2023 – 05/31/2026, 06/01/2023 – 05/31/2025, 06/01/2023 – 05/31/2025) Pass Through Entity: University of Alabama MW2023-002 PROCUREMENT, SUSPENSION AND DEBARMENT Material Weakness Criteria The requirements for this compliance requirement are contained in 2 CFR sections 200.317- 200.326; 48 CFR parts 03, 15, 44, and the clauses at 48 CRF sections 52.244-2, 52.244-5, 52.203-13, 52.203-16 and 52.215-12; agency FAR supplements; 2 CFR part 180; OMB M-18- 18; and the terms and conditions of the federal award. There is a requirement to verify that contractors in covered transactions or any of its vendors are not federally debarred, suspended, or excluded. A covered transaction is a nonprocurement or procurement transaction in excess of $25,000 that is subject to the prohibitions noted in 2 CFR part 180. The covered transaction may be at the primary tier, between a federal agency and a person or a lower tier between a participant in a covered transaction and another person. Condition CUAHSI failed to maintain and provide the proper records and support to document their review of vendor files for covered transactions. Such failure led to non-compliance with the procurement, suspension and debarment policies in accordance with the UG for the year ended December 31, 2023. CUAHSI did not complete the verification of its 2023 vendors until 2024. Based on our testing, no contractors in covered transactions were deemed to be federally debarred, suspended or excluded. Cause & Context CUAHSI has a policy in place to meet the procurement requirements but there was no evidence of compliance with that policy. Effect As a result of noncompliance, there could be possible repayment of funds and / or possible suspension or debarment. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2022-006. Recommendation CUAHSI should ensure that, to the extent practicable, the use of a competitive procurement process in compliance with 2 CFR section 200/317. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHS! impacting audit year 2023: Vendor status for 2023 recipients was retroactively evaluated by CUAHSI staff and certified by management during calendar year 2024. Records were organized and filed in a secure, centralized document management system. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI considers this finding closed, as current practices comply with established policies and procedures. Name of Contact Person: • Maureen S. Ako, Director of Finance • Telephone: (339)221-5400 • Email: msabino@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2022-006

About Procurement and Suspension and Debarment →
2023-003
Subrecipient Monitoring
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation & U.S. Department of Commerce Federal program title: Geosciences, Computer and Information Science and Engineering, Office of International Science and Engineering & NOAA – Cooperative Institute AL No.: 47.050, 47.070, 47.079 & 11.432 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2023), EAR- 2244446 (03/01/2023 – 02/28/2026), OAC-2209833 (01/01/2023 – 12/31/2026), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2024), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026), OISE-1855654 (05/15/2019 – 12/31/2023) & A22NWS4320003 (08/01/2022 – 07/25/2025, 08/01/2022 – 07/25/2025, 04/01/2023 – 03/31/2024, 06/01/2023 – 05/31/2024, 06/01/2023 – 05/31/2026, 06/01/2023 – 05/31/2025, 06/01/2023 – 05/31/2025) Pass Through Entity: University of Alabama MW2023-003 SUBRECIPIENT MONITORING Material Weakness Criteria The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of federal awards should be following federal regulations, the terms of the federal contract, and any additional requirements specified by the auditee's policies and procedures. Specifically, the monitoring criteria should include, but not be limited to, the following: • Subrecipient Risk Assessment • Financial Monitoring • Compliance Monitoring • Reporting and Documentation Condition The auditee failed to comply with federal regulations requiring the monitoring of subrecipients for federal awards on a timely basis. Recipients of federal awards are responsible for monitoring the activities of subrecipients to ensure that they comply with applicable laws, regulations, and the terms and conditions of the federal award. CUAHSI did not complete the monitoring of its 2023 subrecipients until 2024. During the year ended December 31, 2023, CUAHSI had $627,464 in amounts paid to subrecipients. Based on our testing of amounts paid to subrecipients, no amounts were identified as unallowable. Cause & Context CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring. There was no audit evidence of CUAHSI following the policy and monitoring that the subrecipient was using the funding as prescribed during the year ended December 31, 2023. Effect CUAHSI’s lack of monitoring creates a significant risk of the possible misuse or improper use of funds. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2022-005. Recommendation The auditor recommends that management review the requirements documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities) and develops and implements procedures to adhere to such requirements. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHS! impacting audit year 2023: CUAHSI acknowledges that incomplete documentation was available to show subrecipient-monitoring procedures were followed for FY 2023 within the required timeframe. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI now follows a written Subrecipient Monitoring Policy that specifies the duties of the Director of Finance, Staff Accountant, and Principal Investigator. Monitoring of active subawards began in May 2023. The subaward monitoring process was updated on September 21 2023 and further refined in spring 2024. All subrecipients from FY 2020–2023 have been retroactively certified, and timely reviews were in place for awards from FY 2024 onward. Management performs a mid-year check to confirm that monitoring records are complete, adequate, and securely stored. Name of Contact Person: • Jordan S Read, Chief Executive Officer • Telephone: (339)933-4660 • Email: jread@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2022-005

About Subrecipient Monitoring →
2023-004
Cash Management
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering & Office of International Science and Engineering AL No.: 47.050, 47.070 & 47.079 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2023), EAR- 2244446 (03/01/2023 – 02/28/2026), OAC-2209833 (01/01/2023 – 12/31/2026), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2024), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026) & OISE-1855654 (05/15/2019 – 12/31/2023) Pass Through Entity: None MW2023-004 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF EXPENDITURES Material Weakness Criteria CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the management of cash drawdowns and disbursements of federal funds. Federal funds should be disbursed in a timely manner for allowable costs that have been incurred. Cash advances must meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation. Condition CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation which details the requirements for advance fundings. During 2023, CUAHSI had advance drawdowns totaling $4,930,416 from the NSF. Of this amount, CUAHSI incurred $4,463,802 in eligible expenses for the year ended December 31, 2023. This resulted in $466,614 in excess federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2023 are reported as part of the advances payable liability in the accompanying Statement of Financial Position. Cause & Context CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter VIII.C.3 of the grant agreement. Effect Drawing down funds in advance of incurring eligible expenses may result in the need to repay the funds, potential financial penalties, or disqualification from future federal funding. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2022-007. Recommendation The auditor recommends that CUAHSI develops and implements controls over policies consistent with 2 CFR 200.35. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHS! impacting audit year 2023: Certain 2023 draws were processed as advances outside grant guidelines, although these draws were properly recorded as advances payable in the accounting records. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI considers this finding resolved. A written drawdown procedure is now in place, requiring two-tier preparation and review, and, for working-capital advances, written approval from the prime funder. When the non-compliance was identified, CUAHSI suspended all NSF draws (late March 2023) until new controls were implemented. On 15 June 2023, CUAHSI completed its first draw under the revised policy. Name of Contact Person: • Jordan S Read, Chief Executive Officer • Telephone: (339)933-4660 • Email: jread@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2022-007

About Cash Management →

FY 2022-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on July 3, 2025. 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 January 3, 2026, which was (229 days ago).

What is a management decision? →
2022-002
Reporting
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation and U.S. Department of Commerce Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure & NOAA – Cooperative Institute AL No.: 47.050, 47.070, 47.079, 47.080 & 11.432 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC- 1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & A22NWS4320003 (08/01/2022 – 7/25/2025) Pass Through Entity: Utah State University & University of Alabama MW2022-002 ACCURACY AND COMPLETENESS OF SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (“SEFA”) Material Weakness Criteria CUAHSI is required to prepare a SEFA in accordance with the prescribed guidelines of the Uniform Guidance (“UG”). In addition, 2 CFR Section 200.512(a) of the Uniform Guidance requires the reporting package and Data Collection Form (“DCF”) to be submitted to the Federal Audit Clearinghouse the earlier of 30 calendar days after the reports are received from the auditor or nine months after CUAHSI’s year end. Condition CUAHSI provided two different versions of the SEFA to the auditor during the audit process. Additionally, due to the delay in financial close of CUAHSI’s books and records, a federal single audit for the year ended December 31, 2022 was not performed in a timely manner and the DCF was not submitted by its due date of September 30, 2023. The inaccurate reporting of grants and related activity in the SEFA can lead to improper identification of major programs causing inadequate testing by the auditor as required by UG. As a result of the audit procedures performed and proposed adjustments to CUAHSI’s preliminary SEFA by the audit, management was able to make the required changes.Cause & Context Due personnel and staffing issues, CUAHSI was not able to complete the financial close process in a timely manner which led to the changes in qualified expenditures and delay in the financial statement and the federal single audit being completed. Effect Failure to comply with federal regulations and reporting requirements exposes CUAHSI to potential legal and regulatory consequences, including the risk of future funding loss and financial penalties. Questioned Costs None Prior Year Audit Finding Yes - previously reported as MW2021-002. Recommendation To address the identified deficiencies and improve controls over the preparation of the SEFA, the auditor recommends the development and documentation of procedures for tracking federal awards and related disbursements to subrecipients. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Finding Reference Number: MW2022-002 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2022: CUAHSI’s accounting and finance staff prepared the 2022 SEFA and delivered it to the auditors before the 2021 audit was complete. When the 2021 audit closed, closing adjustments were posted, and those entries (rather than any preparation error) required a corresponding update to the 2022 SEFA Corrective actions to processes and responsibilities impacting subsequent years: This finding is considered resolved through the hiring of new CUAHSI employees in September 2023, who have the capability to manage single-audit preparation, oversee grants and agreements, and maintain appropriate internal controls. In addition, policies and documentation practices have been updated to strengthen oversight. The current accounting system—fully implemented in 2023—now supports all required grant tracking, segregation, and reporting. Name of Contact Person: • Jordan S Read, Executive Director • Telephone: (339)933-4660 • Email: jread@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2021-002

About Reporting →
2022-004
Reporting
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation and U.S. Department of Commerce Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure & NOAA – Cooperative Institute AL No.: 47.050, 47.070, 47.079, 47.080 & 11.432 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC- 1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & A22NWS4320003 (08/01/2022 – 7/25/2025) Pass Through Entity: Utah State University & University of Alabama MW2022-004 REPORTING - DCF Material Weakness Criteria 2 CFR Section 200.512(a) requires the reporting package and DCF to be submitted to the Federal Audit Clearinghouse the earlier of thirty calendar days after the reports are received from the auditor or nine months after the end of the audit period. Condition Due to the delay in financial close of CUAHSI’s books and records, a federal single audit for fiscal year 2022 was not performed in a timely manner and the DCF was not submitted by its due date of September 30, 2023. The UG requires the reporting package and DCF to be submitted to the Federal Audit Clearinghouse the earlier of 30 calendar days after the reports are received from the auditor (June 27, 2025) or nine months after CUAHSI’s year end (September 30, 2023). Cause & Context CUAHSI did not have effective controls in place to allow for a timely year-end closing. This caused significant auditor delays which resulted in CUAHSI’s inability to meet the filing requirements under the UG.Effect CUAHSI is not in compliance with 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2021-004. Recommendation Management should implement policies to ensure timely financial reporting and ensure the timely completion of an audit. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Finding Reference Number: MW2022-004 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2022: NA Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI is behind on submitting audits for fiscal years (FY) 2022 and 2023. Management has made clearing this backlog its highest priority. The schedule is to complete and file the FY 2022 audit package in mid-2025, the FY 2023 package by fall 2025, and the FY 2024 package by the end of calendar-year 2025, at which point CUAHSI expects to return to on-time Federal Audit Clearinghouse filings. Recent upgrades to the accounting system, the hiring of in-house finance staff, and revised closing procedures are designed to streamline and accelerate future audit preparation so that all subsequent audits are filed by the required deadlines. Name of Contact Person: • Maureen S. Ako, Director of Finance • Telephone: (339)221-5400 • Email: msabino@cuahsi.org Projected Completion Date: 2025-12-31

Prior Finding References

2021-004

About Reporting →
2022-005
Subrecipient Monitoring
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering & Office of Cyber Infrastructure AL No.: 47.050, 47.070, 47.079 & 47.080 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC- 1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023) & OAC-1664061 (10/01/17 – 09/30/2022) Pass Through Entity: Utah State University MW2022-005 SUBRECIPIENT MONITORING Material Weakness Criteria The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of federal awards should be following federal regulations, the terms of the federal contract, and any additional requirements specified by the auditee's policies and procedures. Specifically, the monitoring criteria should include, but not be limited to, the following: • Subrecipient Risk Assessment • Financial Monitoring • Compliance Monitoring • Reporting and Documentation Condition The auditee failed to comply with federal regulations requiring the monitoring of subrecipients for federal awards on a timely basis. Recipients of federal awards are responsible for monitoring the activities of subrecipients to ensure that they comply with applicable laws, regulations, and the terms and conditions of the federal award. CUAHSI did not complete the monitoring of its 2022 subrecipients until 2024. During the year ended December 31, 2022, CUAHSI had $252,550 in amounts paid to subrecipients. Based on our testing of amounts paid to subrecipients, no amounts were identified as unallowable.Material Weakness Cause & Context CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring. There was no audit evidence of CUAHSI following the policy and monitoring that the subrecipient was using the funding as prescribed during the year ended December 31, 2022. Effect CUAHSI’s lack of monitoring creates a significant risk of the possible misuse or improper use of funds. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2021-005. Recommendation The auditor recommends that management review the requirements documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities) and develops and implements procedures to adhere to such requirements. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Finding Reference Number: MW2022-005 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2022: CUAHSI acknowledges that no documentation was available to show subrecipient-monitoring procedures were followed for FY 2022 within the required timeframe. In 2023, a targeted review of all active subawards 2022 was conducted. That effort was then expanded to include (i) written recipient self-certifications and (ii) a formal, documented risk-assessment workflow for CUAHSI management. Retroactive monitoring for every FY 2022 subaward was completed and filed under this enhanced process in spring 2024. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI now follows a written Subrecipient Monitoring Policy that specifies the duties of the Director of Finance, Staff Accountant, and Principal Investigator. Routine monitoring of active subawards began in May 2023; the process was updated on September 21 2023 and further strengthened in spring 2024. All subrecipients from FY 2020–2022 have been retroactively certified, and timely reviews were in place for FY 2023–2024 awards. Management performs a mid-year check to confirm that monitoring records are complete, adequate, and securely stored. Name of Contact Person: • Jordan S Read, Executive Director • Telephone: (339)933-4660 • Email: jread@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2021-005

About Subrecipient Monitoring →
2022-006
Procurement & Suspension/Debarment
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering & Office of Cyber Infrastructure AL No.: 47.050, 47.070, 47.079 & 47.080 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC- 1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023) & OAC-1664061 (10/01/17 – 09/30/2022) Pass Through Entity: Utah State University MW2022-006 PROCUREMENT, SUSPENSION AND DEBARMENT Material Weakness Criteria The requirements for this compliance requirement are contained in 2 CFR sections 200.317- 200.326; 48 CFR parts 03, 15, 44, and the clauses at 48 CRF sections 52.244-2, 52.244-5, 52.203-13, 52.203-16 and 52.215-12; agency FAR supplements; 2 CFR part 180; OMB M-18- 18; and the terms and conditions of the federal award. There is a requirement to verify that contractors in covered transactions or any of its vendors are not federally debarred, suspended, or excluded. A covered transaction is a nonprocurement or procurement transaction in excess of $25,000 that is subject to the prohibitions noted in 2 CFR part 180. The covered transaction may be at the primary tier, between a federal agency and a person or a lower tier between a participant in a covered transaction and another person. Condition The auditor noted that CUAHSI failed to maintain and provide the proper records and support to document their review of vendor files for covered transactions. Such failure led to noncompliance with the procurement, suspension and debarment policies in accordance with the UG for the year ended December 31, 2022. CUAHSI did not complete the verification of its 2022 vendors until 2024. Based on our testing, no contractors in covered transactions were deemed to be federally debarred, suspended or excluded.Cause & Context CUAHSI has a policy in place to meet the procurement requirements but there was no evidence of compliance with that policy. Effect As a result of noncompliance, there could be possible repayment of funds and / or possible suspension or debarment. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2021-007. Recommendation CUAHSI should ensure that, to the extent practicable, the use of a competitive procurement process in compliance with 2 CFR section 200/317. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Finding Reference Number: MW2022-006 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2022: Vendor status for 2022 recipients was retroactively evaluated by CUAHSI staff and certified by management during calendar year 2024. Records were organized and filed in a secure, centralized document management system. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI considers this finding closed, as current practices comply with established policies and procedures. Name of Contact Person: • Maureen S. Ako, Director of Finance • Telephone: (339)221-5400 • Email: msabino@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2021-007

About Procurement and Suspension and Debarment →
2022-007
Cash Management
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering & Office of Cyber Infrastructure AL No.: 47.050, 47.070, 47.079 & 47.080 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC- 1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023) & OAC-1664061 (10/01/17 – 09/30/2022) Pass Through Entity: Utah State University MW2022-007 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF EXPENDITURES Material Weakness Criteria CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the management of cash drawdowns and disbursements of federal funds. Federal funds should be disbursed in a timely manner for allowable costs that have been incurred. Cash advances must meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation. Condition CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation which details the requirements for advance fundings. During 2022, CUAHSI had advance drawdowns totaling $3,862,318 from the NSF. Of this amount, CUAHSI incurred $3,228,996 in eligible expenses for the year ended December 31, 2022. This resulted in $633,322 in excess federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2022 are reported as part of advances payable in the accompanying Statement of Financial Position. Cause & Context CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter VIII.C.3 of the grant agreement.Effect Drawing down funds in advance of incurring eligible expenses could lead to non-compliance with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need to repay the funds, potential financial penalties, or disqualification from future federal funding. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2021-008. Recommendation The auditor recommends that CUAHSI develops and implements controls over policies consistent with 2 CFR 200.35. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Finding Reference Number: MW2022-07 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2022: Certain 2022 draws were processed as advances outside grant guidelines, although these draws were properly recorded as advances payable in the accounting records. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI considers this finding resolved. A written drawdown procedure is now in place, requiring twotier preparation and review and, for working-capital advances, written approval from the prime funder. When the non-compliance was identified, CUAHSI suspended all NSF draws (late March 2023) until new controls were implemented. On 15 June 2023 CUAHSI completed its first draw under the revised policy; the certified SF-270 and supporting documentation were reviewed and approved by NSF. Name of Contact Person: • Jordan S Read, Executive Director • Telephone: (339)933-4660 • Email: jread@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2021-008

About Cash Management →
2022-008
Program Income
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering & Office of Cyber Infrastructure AL No.: 47.050, 47.070, 47.079 & 47.080 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC- 1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023) & OAC-1664061 (10/01/17 – 09/30/2022) Pass Through Entity: Utah State University MW2022-008 PROGRAM INCOME Material Weakness Criteria Pursuant to 2 CFR 200 for award objectives and the regulations at 2 CFR 200.307, program income is defined as “Gross income earned by the recipient that is directly generated by a supported activity or earned as a result of the federal award during the period of performance” by 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards. Program income reporting is due forty five (45) days after the end of the federal fiscal year. NSF requires that all cumulative program income is reported for all open grants and agreements in the current year. Condition Program income consists of registration fees collected for training, meetings or workshops and the proceeds from the sale of publications as a result of the federal award during the period of performance. Program income is treated as an additive to the federal funds received by CUAHSI. During a drawdown, program income reduces the amount that is requested to cover reimbursable costs through the Flexible Billing module. This allows program income to be applied to the award before a reimbursement is requested from NSF adding the value of program income received to the awarded amount. Program income reporting is due forty five (45) days after the end of the federal fiscal year. NSF requires that all cumulative program income is reported for all open grants and agreements in the current year. CUAHSI program income totaled $12,605 for the year ended December 31, 2022.CUAHSI failed to submit the required Program Income Reporting Worksheet by the required deadline of forty five (45) days after the end of the federal fiscal year (November 15, 2022) to ensure with the program income policies in accordance with the UG for the year ended December 31, 2022. Cause & Context Lack of resources and detailed attention to the risks, along with circumvention of controls has resulted in weak internal controls, and conflicting or incomplete policies and procedures. Effect Non-compliance can lead to penalties, fines, or even termination of the contract. It may also damage CUAHSI’s future eligibility for federal funding and jeopardize CUAHSI’s ability to secure future grants or contracts from other funding agencies. Granting organizations typically prioritize funding recipients with a track record of compliance and accountability. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2021-009. Recommendation The auditor recommends that CUAHSI develops and implements controls over policies consistent with 2 CFR 200.307.View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Finding Reference Number: MW2022-008 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2022: External contract accounting staff in place during audit year 2022 failed to declare program income in advance of the deadline specified by NSF. Program income for 2022 was filed was filed on 3 December 2022, approximately three weeks late. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI continues to use a single payment gateway for events and registration fees which supports segregation of payments per event and per grant. Program income has been reported to NSF accurately and on time as of audit year 2023 and appropriate staff and policies are in place to ensure continued future compliance. Name of Contact Person: • Maureen S. Ako, Director of Finance • Telephone: (339)221-5400 • Email: msabino@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2021-009

About Program Income →

FY 2021-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on April 6, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by October 6, 2025, which was (318 days ago).

What is a management decision? →
2021-002
Reporting
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure, Integrative Activities & Forestry Research AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC- 1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020 – 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021) Pass Through Entity: Utah State University & University of Cincinnati MW2021-002 ACCURACY AND COMPLETENESS OF SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (“SEFA”) Material Weakness Criteria CUAHSI is required to prepare a SEFA in accordance with the prescribed guidelines of the Uniform Guidance (“UG”). In addition, 2 CFR Section 200.512(a) of the Uniform Guidance requires the reporting package and Data Collection Form (“DCF”) to be submitted to the Federal Audit Clearinghouse the earlier of 30 calendar days after the reports are received from the auditor or nine months after CUAHSI’s year end. Condition CUAHSI provided two different versions of the SEFA to the auditor during the audit process. Additionally, due to the delay in financial close of CUAHSI’s books and records, a federal single audit for the year ended December 31, 2021 was not performed in a timely manner and the DCF was not submitted by its due date of September 30, 2022. The inaccurate reporting of grants and related activity in the SEFA can lead to improper identification of major programs causing inadequate testing by the auditor as required by UG. As a result of the audit procedures performed and proposed adjustments to CUAHSI’s preliminary SEFA by the audit, management was able to make the required changes. Cause & Context Due personnel and staffing issues, CUAHSI was not able to complete the financial close process in a timely manner which led to the changes in qualified expenditures and delay in the financial statement and the federal single audit being completed. Effect Failure to comply with federal regulations and reporting requirements exposes CUAHSI to potential legal and regulatory consequences, including the risk of future funding loss and financial penalties. Questioned Costs None Prior Year Audit Finding Yes - previously reported as MW2020-002. Recommendation To address the identified deficiencies and improve controls over the preparation of the SEFA, the auditor recommends the development and documentation of procedures for tracking federal awards and related disbursements to subrecipients. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Finding Reference Number: MW2021-002 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2021: CUAHSI’s current accounting and finance staff successfully completed the 2021 SEFA. However, revisions to the version initially shared with auditors were necessary to correct expenses improperly categorized by prior contracted accounting staff during a migration from a failing legacy system to an enterprise accounting system. Some expenses had to be reclassified to convert the book of accounts from cash basis to accrual basis. These errors stemmed from the loss of staff familiar with the original terms of a legacy agreement, poor document management practices, and inadequate oversight during the 2022 migration to the new accounting system. Corrective actions to processes and responsibilities impacting subsequent years: This finding is considered resolved through the hiring of new CUAHSI employees in September 2023, who have the capability to manage single audit preparation, oversee grants and agreements, and maintain appropriate internal controls. In addition, policies and documentation practices have been updated to strengthen oversight. The current accounting system—fully implemented in 2023—now supports all required grant tracking, segregation, and reporting. Name of Contact Person: 􀁸 Jordan S Read, Executive Director 􀁸 Telephone: (339)933-4660 􀁸 Email: jread@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2020-002

About Reporting →
2021-004
Reporting
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure, Integrative Activities & Forestry Research AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC- 1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020 – 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021) Pass Through Entity: Utah State University & University of Cincinnati MW2021-004 REPORTING - DCF Material Weakness Criteria 2 CFR Section 200.512(a) requires the reporting package and DCF to be submitted to the Federal Audit Clearinghouse the earlier of thirty calendar days after the reports are received from the auditor or nine months after the end of the audit period. Condition Due to the delay in financial close of CUAHSI’s books and records, a federal single audit for fiscal year 2021 was not performed in a timely manner and the DCF was not submitted by its due date of September 30, 2022. The UG requires the reporting package and DCF to be submitted to the Federal Audit Clearinghouse the earlier of 30 calendar days after the reports are received from the auditor (April 2, 2025) or nine months after CUAHSI’s year end (September 30, 2022). Cause & Context CUAHSI did not have effective controls in place to allow for a timely year-end closing. This caused significant auditor delays which resulted in CUAHSI’s inability to meet the filing requirements under the UG. Effect CUAHSI is not in compliance with 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2020-004. Recommendation Management should implement policies to ensure timely financial reporting and ensure the timely completion of an audit. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Finding Reference Number: MW2021-004 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2021 NA Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI is currently delinquent on the filing of audits from fiscal years 2021-2023. The organization is treating audit filings as the top priority and is working carefully through the audit backlog with qualified auditors that are currently engaged for audits 2021-2022. The delays in filing will continue into calendar year 2025, at which time it is expected that the audit package for the year ended December 31, 2024, will be filed on time to the Federal Audit Clearinghouse. Changes to CUAHSI’s accounting system, personnel, duties, and processes help ensure future audit preparation and support are streamlined, accurate, and timely. Name of Contact Person: 􀁸 Maureen S. Ako, Director of Finance 􀁸 Telephone: (339)221-5400 􀁸 Email: msabino@cuahsi.org Projected Completion Date: 2025-09-30

Prior Finding References

2020-004

About Reporting →
2021-005
Subrecipient Monitoring
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure & Integrative Activities AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC- 1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099 (09/01/2020 – 08/31/2021) Pass Through Entity: Utah State University & University of Cincinnati MW2021-005 SUBRECIPIENT MONITORING Material Weakness Criteria The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of federal awards should be following federal regulations, the terms of the federal contract, and any additional requirements specified by the auditee's policies and procedures. Specifically, the monitoring criteria should include, but not be limited to, the following: • Subrecipient Risk Assessment • Financial Monitoring • Compliance Monitoring • Reporting and Documentation Condition The auditee failed to comply with federal regulations requiring the monitoring of subrecipients for federal awards on a timely basis. Recipients of federal awards are responsible for monitoring the activities of subrecipients to ensure that they comply with applicable laws, regulations, and the terms and conditions of the federal award. CUAHSI did not complete the monitoring of its 2021 subrecipients until 2024. During the year ended December 31, 2021, CUAHSI had $128,472 in amounts paid to subrecipients. Based on our testing of amounts paid to subrecipients, no amounts were identified as unallowable. Cause & Context CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring. There was no audit evidence of CUAHSI following the policy and monitoring that the subrecipient was using the funding as prescribed during the year ended December 31, 2021. Effect CUAHSI’s lack of monitoring creates a significant risk of the possible misuse or improper use of funds. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2020-005. Recommendation The auditor recommends that management review the requirements documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities) and develops and implements procedures to adhere to such requirements. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Finding Reference Number: MW2021-005 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2021: CUAHSI agrees with the findings that no documentation was available to demonstrate subrecipient monitoring policies were followed during audit year 2021 or within a reasonable timeframe thereafter. A limited subaward monitoring review of 2021’s active awards were performed in 2023. This review was subsequently expanded to include recipient self-certification and CUAHSI management risk assessments, with full retroactive subaward monitoring of 2021 recipients completed and filed in spring 2024. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI maintains a subrecipient monitoring policy outlining the duties and responsibilities of the Director of Finance, Accountant, and Principal Investigator. Subrecipient monitoring progress for active awards began in May 2023, with the process updated on September 21, 2023, and finalized in spring 2024. This effort included retroactive certification for subaward recipients from fiscal years 2020–2022, along with timely review and filing for audit year 2023. CUAHSI management verifies adherence to these policies through a mid-year process review, ensuring all documentation is complete, adequate, and securely organized. Name of Contact Person: 􀁸 Jordan S Read, Executive Director 􀁸 Telephone: (339)933-4660 􀁸 Email: jread@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2020-005

About Subrecipient Monitoring →
2021-006
Cash Management
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure & Integrative Activities AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC- 1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099 (09/01/2020 – 08/31/2021) Pass Through Entity: Utah State University & University of Cincinnati Material Weakness MW2021-006 CASH MANAGEMENT Criteria 2 CFR Part 200 states that entities expending federal grants must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the Federal award. To comply with 2 CFR Part 200, CUAHSI was required to submit monthly invoices for the funds received under the federal contract. These invoices will serve as a record of the services or goods provided during the specified period and will facilitate accurate tracking and reporting of the funds. In addition to the invoice, any supporting documentation, such as timesheets, should be maintained with the invoices. The cash management process should also be adjusted for the receipt of program income. These documents validate the services provided and ensure transparency and auditability of the invoiced amount. These amounts should be able to be traced to the general ledger in conjunction with the time in which they are billed. Condition The cash management process requires that cash draws be reviewed and approved to ensure the propriety of draw reimbursement requests. Management was unable to provide the auditor evidence documenting approval of the drawdowns for the year ended December 31, 2021. Cause & Context CUAHSI had no fiscal management team during the year ended December 31, 2021 to ensure compliance with proper policies and procedures. The books and records for the year ended December 31, 2021 were recreated by the current management team during 2024 to 2025. Effect Grant awards and reimbursements may not be recorded correctly and there is a higher risk of error or misappropriation of assets. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2020-006. Recommendation The auditor recommends CUAHSI develop and implement controls to ensure an adequate review process is in place for review of reimbursement requests submitted to granting agencies to ensure consistent reporting. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Finding Reference Number: MW2021-006 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2021: CUAHSI was unable to produce supporting documentation substantiating expenses behind numerous cash draws from NSF during audit year 2021. Corrective actions to processes and responsibilities impacting subsequent years: As of June 15th, 2023, all CUAHSI draws from NSF awards include supporting documents for expenses and a certified SF-270. The SF-270 and documents are stored in a secure and organized document management system. Per CUAHSI’s updated policies, each draw follows segregation of duties and an internal review, approval, and certification process. CUAHSI’s Operations and Program Assistant reviews documents quarterly to ensure all certified draw requests are filed along with associated backup and reports status to Management and relevant CUAHSI Officers (e.g., Treasurer) to ensure policy adherence. Name of Contact Person: 􀁸 Maureen S. Ako, Director of Finance 􀁸 Telephone: (339)221-5400 􀁸 Email: msabino@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2020-006

About Cash Management →
2021-007
Procurement & Suspension/Debarment
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure & Integrative Activities AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC- 1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099 (09/01/2020 – 08/31/2021) Pass Through Entity: Utah State University & University of Cincinnati MW2021-007 PROCUREMENT, SUSPENSION AND DEBARMENT Material Weakness Criteria The requirements for this compliance requirement are contained in 2 CFR sections 200.317- 200.326; 48 CFR parts 03, 15, 44, and the clauses at 48 CRF sections 52.244-2, 52.244-5, 52.203-13, 52.203-16 and 52.215-12; agency FAR supplements; 2 CFR part 180; OMB M-18- 18; and the terms and conditions of the federal award. There is a requirement to verify that contractors in covered transactions or any of its vendors are not federally debarred, suspended, or excluded. A covered transaction is a nonprocurement or procurement transaction in excess of $25,000 that is subject to the prohibitions noted in 2 CFR part 180. The covered transaction may be at the primary tier, between a federal agency and a person or a lower tier between a participant in a covered transaction and another person. Condition During the completion of the audit, the auditor noted that CUAHSI failed to maintain and provide the proper records and support to document their review of vendor files for covered transactions. Such failure led to non-compliance with the procurement, suspension and debarment policies in accordance with the UG for the year ended December 31, 2021. CUAHSI did not complete the verification of its 2021 vendors until 2024. Based on our testing, no contractors in covered transactions were deemed to be federally debarred, suspended or excluded. Material Weakness Cause & Context CUAHSI has a policy in place to meet the procurement requirements but there was no evidence of compliance with that policy. Effect As a result of noncompliance, there could be possible repayment of funds, loss of reputation and possible suspension or debarment. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2020-007. Recommendation It is recommended that CUAHSI strive to prioritize compliance. CUAHSI should ensure that, to the extent practicable, the use of a competitive procurement process in compliance with 2 CFR section 200/317. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Finding Reference Number: MW2021-007 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2021: Vendor status for 2021 recipients was retroactively evaluated by CUAHSI staff and certified by management during calendar year 2024. Records were organized and filed in a secure, centralized document management system. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI considers this finding closed, as current practices comply with established policies and procedures. Vendor onboarding now includes a required disbarment check conducted by the Director of Finance. In 2024, new procurement requirements were added to clarify thresholds and competitive procurement processes, and an approval certification step was implemented for all vendor payments. This monthly certification, performed by the Director of Finance or Executive Director, ensures that payment recipients are not suspended or disbarred. Name of Contact Person: 􀁸 Maureen S. Ako, Director of Finance 􀁸 Telephone: (339)221-5400 􀁸 Email: msabino@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2020-007

About Procurement and Suspension and Debarment →
2021-008
Cash Management
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure & Integrative Activities AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC- 1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099 (09/01/2020 – 08/31/2021) Pass Through Entity: Utah State University & University of Cincinnati MW2021-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF EXPENDITURES Material Weakness Criteria CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the management of cash drawdowns and disbursements of federal funds. Federal funds should be disbursed in a timely manner for allowable costs that have been incurred. Cash advances must meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation. Condition CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation which details the requirements for advance fundings. During 2021, CUAHSI had advance drawdowns totaling $1,172,645 from the NSF. Of this amount, CUAHSI incurred $1,049,681 in eligible expenses for the year ended December 31, 2021. This resulted in $122,964 in excess federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2021 are reported as part of deferred revenue in the accompanying Statement of Financial Position. Cause & Context CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter VIII.C.3 of the grant agreement. Effect Drawing down funds in advance of incurring eligible expenses could lead to non-compliance with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need to repay the funds, potential financial penalties, or disqualification from future federal funding. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2020-008. Recommendation The auditor recommends that CUAHSI develops and implements controls over policies consistent with 2 CFR 200.35. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Finding Reference Number: MW2021-08 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2021: All advance draws in 2021 were properly recorded as deferred revenue in the accounting books, see Statement of Financial Position. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI consider this finding resolved. As covered in the corrective action to MW2021-006, CUAHSI implemented the drawdown procedure as documented in company policy which includes twotiered preparation and review and requires review and approval by the Prime funder for working capital advances. CUAHSI stopped the non-compliance in 2023 by halting all draws against NSF awards in late March 2023 (when this non-compliance became known to the current Executive Director) until June 15th, 2023, at which time CUAHSI completed a draw from an NSF aligned with the current policies. The certified SF-270 and draw documentation was reviewed and approved by NSF. Name of Contact Person: 􀁸 Jordan S Read, Executive Director 􀁸 Telephone: (339)933-4660 􀁸 Email: jread@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2020-008

About Cash Management →
2021-009
Program Income
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure & Integrative Activities AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC- 1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099 (09/01/2020 – 08/31/2021) Pass Through Entity: Utah State University & University of Cincinnati MW2021-009 PROGRAM INCOME Material Weakness Criteria Pursuant to 2 CFR 200 for award objectives and the regulations at 2 CFR 200.307, program income is defined as “Gross income earned by the recipient that is directly generated by a supported activity or earned as a result of the federal award during the period of performance” by 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards. Program income reporting is due forty five (45) days after the end of the federal fiscal year. NSF requires that all cumulative program income is reported for all open grants and agreements in the current year. Condition Program income consists of registration fees collected for training, meetings or workshops and the proceeds from the sale of publications as a result of the federal award during the period of performance. Program income is treated as an additive to the federal funds received by CUAHSI. During a drawdown, program income reduces the amount that is requested to cover reimbursable costs through the Flexible Billing module. This allows program income to be applied to the award before a reimbursement is requested from NSF adding the value of program income received to the awarded amount. Program income reporting is due forty five (45) days after the end of the federal fiscal year. NSF requires that all cumulative program income is reported for all open grants and agreements in the current year. CUAHSI program income totaled $31,525 for the year ended December 31, 2021. CUAHSI failed to submit the required Program Income Reporting Worksheet by the required deadline of forty five (45) days after the end of the federal fiscal year (November 15, 2021) to ensure with the program income policies in accordance with the UG for the year ended December 31, 2021. Cause & Context Lack of resources and detailed attention to the risks, along with circumvention of controls has resulted in weak internal controls, and conflicting or incomplete policies and procedures. Effect Non-compliance can lead to penalties, fines, or even termination of the contract. It may also damage CUAHSI’s reputation and future eligibility for federal funding and jeopardize CUAHSI’s ability to secure future grants or contracts from other funding agencies. Granting organizations typically prioritize funding recipients with a track record of compliance and accountability. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2020-009. Recommendation The auditor recommends that CUAHSI develops and implements controls over policies consistent with 2 CFR 200.307. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Finding Reference Number: MW2021-009 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2021: CUAHSI used a single payment gateway for registration on CUAHSI events and was able to accurately document and produce grant-specific totals for audit year 2021 program income. CUAHSI staff missed the NSF filing deadline for declaring federal fiscal year 2021 program income by one day (submitted November 16th, 2021). Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI continues to use a single payment gateway for events and registration fees which supports segregation of payments per event and per grant. Program income has been reported to NSF accurately and on time beginning in 2023 and appropriate staff and policies are in place to ensure future compliance. Name of Contact Person: 􀁸 Maureen S. Ako, Director of Finance 􀁸 Telephone: (339)221-5400 􀁸 Email: msabino@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2020-009

About Program Income →

FY 2020-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on February 28, 2025. 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 August 28, 2025, which was (357 days ago).

What is a management decision? →
2020-002
Reporting
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure, Integrative Activities & Forestry Research AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020 – 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021) Pass Through Entity: Utah State University & University of Cincinnati MW2020-002 ACCURACY AND COMPLETENESS OF SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (“SEFA”) Criteria CUAHSI is required to prepare a SEFA in accordance with the prescribed guidelines of the Uniform Guidance (“UG”). In addition, 2 CFR Section 200.512(a) of the Uniform Guidance requires the reporting package and Data Collection Form (“DCF”) to be submitted to the Federal Audit Clearinghouse the earlier of 30 calendar days after the reports are received from the auditor or nine months after CUAHSI’s year end. Condition CUAHSI provided two different versions of the SEFA to the auditor during the audit process. The auditor noted CUAHSI incorrectly identified the qualified expenditures related to the federal grant programs. Additionally, due to the delay in financial close of CUAHSI’s books and records, a federal single audit for the year ended December 31, 2020 was not performed in a timely manner and the DCF was not submitted by its due date of March 31, 2022. The inaccurate reporting of grants and related activity in the SEFA can lead to improper identification of major programs causing inadequate testing by the auditor as required by UG. As a result of the audit procedures performed and proposed adjustments to CUAHSI’s preliminary SEFA by the audit, management was able to make the required changes. Cause & Context Due personnel and staffing issues, CUAHSI was not able to complete the financial close process in a timely manner which led to the changes in qualified expenditures and delay in the financial statement and the federal single audit being completed. Effect Failure to comply with federal regulations and reporting requirements exposes CUAHSI to potential legal and regulatory consequences, including the risk of future funding loss and financial penalties. Questioned Costs None Prior Year Audit Finding Yes - previously reported as MW2019-006. Recommendation To address the identified deficiencies and improve controls over the preparation of the SEFA, the auditor recommends the development and documentation of procedures for tracking federal awards and related disbursements to subrecipients. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Finding Reference Number: MW2020-002 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2020: CUAHSI replaced prior contracted accounting staff with knowledgeable employees and were able to complete the 2020 SEFA. A lack of organized grant documentation and mistakes by prior contract staff to adequately segregate qualified expenditures from two grants (phase I and phase II of similarly named subawards) required a revision to the initially submitted SEFA to correct the statement of expenses for audit year 2020. Corrective actions to processes and responsibilities impacting subsequent years: We consider this finding to be addressed by new CUAHSI employees hired in September 2023 capable of supporting single audit preparation and updates to policies and documentation storage practices. CUAHSI’s current accounting system – the result of completing a migration from a poorly performing system in 2023 – supports all necessary grant tracking, segregation, and reporting requirements. Name of Contact Person: 􀁸 Jordan S Read, Executive Director 􀁸 Telephone: (339)933-4660 􀁸 Email: jread@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2019-006

About Reporting →
2020-004
Reporting
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure, Integrative Activities & Forestry Research AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020 – 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021) Pass Through Entity: Utah State University & University of Cincinnati MW2020-004 REPORTING - DCF Criteria 2 CFR Section 200.512(a) requires the reporting package and DCF to be submitted to the Federal Audit Clearinghouse the earlier of thirty calendar days after the reports are received from the auditor or nine months after the end of the audit period. Condition Due to the delay in financial close of CUAHSI’s books and records, a federal single audit for fiscal year 2020 was not performed in a timely manner and the DCF was not submitted by its due date of March 31, 2022 (COVID-19 extension). The UG requires the reporting package and DCF to be submitted to the Federal Audit Clearinghouse the earlier of 30 calendar days after the reports are received from the auditor (January 20, 2025) or nine months after CUAHSI’s year end (September 30, 2021) that was extended to March 31, 2022 due to COVID-19. Cause & Context CUAHSI did not have effective controls in place to allow for a timely year-end closing. This caused significant auditor delays which resulted in CUAHSI’s inability to meet the filing requirements under the UG. Effect CUAHSI is not in compliance with 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2019-007. Recommendation Management should implement policies to ensure timely financial reporting and ensure the timely completion of an audit. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Finding Reference Number: MW2020-004 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2020: NA Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI is currently delinquent on the filing of audits from fiscal years 2020-2023. The organization is treating audit filings as the top priority and is working carefully through the audit backlog with qualified auditors that are currently engaged for audits 2020-2022. The delays in filing will continue into calendar year 2025, at which time it is expected that the audit package for the year ended December 31, 2024 will be filed on time to the Federal Audit Clearinghouse. Changes to CUAHSI’s accounting system, personnel, duties, and processes help ensure future audit preparation and support are streamlined, accurate, and timely. Name of Contact Person: 􀁸 Maureen S. Ako, Director of Finance 􀁸 Telephone: (339)221-5400 􀁸 Email: msabino@cuahsi.org Projected Completion Date: 2025-09-30

Prior Finding References

2019-007

About Reporting →
2020-005
Subrecipient Monitoring
REPEATMATERIAL WEAKNESS
Condition

MW2020-005 SUBRECIPIENT MONITORING (REPEAT FINDING) (PREVIOUSLY REPORTED AS MW2019-002) Condition The auditee failed to comply with federal regulations requiring the monitoring of subrecipients for federal awards. Recipients of federal awards are responsible for monitoring the activities of subrecipients to ensure that they comply with applicable laws, regulations, and the terms and conditions of the federal award. The auditee did not maintain any documentation to demonstrate that they fulfilled this responsibility. This noncompliance with the monitoring requirement could result in the mismanagement of federal funds, including the inappropriate expenditure of funds or the failure to achieve program objectives. Criteria The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of federal awards should be following federal regulations, the terms of the federal contract, and any additional requirements specified by the auditee's policies and procedures. Specifically, the monitoring criteria should include, but not be limited to, the following: • Subrecipient Risk Assessment • Financial Monitoring • Compliance Monitoring • Reporting and Documentation Cause CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring. The was no audit evidence of anyone following it and monitoring that the subrecipient was using the funding as prescribed. There was a lack of management oversight.Effect CUAHSI is not in compliance with the requirements for monitoring and thus creating the possible misuse or improper use of funds. Recommendation The auditor recommends that management review the requirements documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities) and develops and implements procedures to adhere to such requirements. Current Year Status This condition still exists for the year ended December 31, 2020. The monitoring of subrecipients was not completed in a reasonable timeframe in accordance with the policies set forth in the UG. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2020: CUAHSI agrees with the finding that no documentation was available to demonstrate subrecipient monitoring policies were followed during audit year 2020 or within a reasonable timeframe thereafter. Subaward monitoring review and certification for 2020 was performed retroactively in 2023. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI has a compliant subrecipient monitoring policy which outlines duties and responsibilities for existing roles covered by CUAHSI staff (primarily, Director of Finance, Accountant, and Principal Investigator). CUAHSI began documenting subrecipient monitoring progress of active awards in May of 2023 and established an updated process on September 21, 2023. CUAHSI Management ensure staff are following these policies via a mid-year process review that verifies documentation is complete, adequate, and is stored securely in an organized manner. Name of Contact Person: 􀁸 Jordan S Read, Executive Director 􀁸 Telephone: (339)933-4660 􀁸 Email: jread@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2019-002

About Subrecipient Monitoring →
2020-005
Subrecipient Monitoring
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure & Integrative Activities AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099 (09/01/2020 – 08/31/2021) Pass Through Entity: Utah State University & University of Cincinnati MW2020-005 SUBRECIPIENT MONITORING Criteria The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of federal awards should be following federal regulations, the terms of the federal contract, and any additional requirements specified by the auditee's policies and procedures. Specifically, the monitoring criteria should include, but not be limited to, the following: • Subrecipient Risk Assessment • Financial Monitoring • Compliance Monitoring • Reporting and Documentation Condition The auditee failed to comply with federal regulations requiring the monitoring of subrecipients for federal awards on a timely basis. Recipients of federal awards are responsible for monitoring the activities of subrecipients to ensure that they comply with applicable laws, regulations, and the terms and conditions of the federal award. CUAHSI did not complete the monitoring of its 2020 subrecipients until 2024. During the year ended December 31, 2020, CUAHSI had $206,636 in amounts paid to subrecipients. Based on our testing of amounts paid to subrecipients, no amounts were identified as unallowable. Cause & Context CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring. There was no audit evidence of CUAHSI following the policy and monitoring that the subrecipient was using the funding as prescribed during the year ended December 31, 2020. Effect CUAHSI’s lack of monitoring creates a significant risk of the possible misuse or improper use of funds. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2019-002. Recommendation The auditor recommends that management review the requirements documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities) and develops and implements procedures to adhere to such requirements. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Finding Reference Number: MW2020-005 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2020: CUAHSI agrees with the finding that no documentation was available to demonstrate subrecipient monitoring policies were followed during audit year 2020 or within a reasonable timeframe thereafter. Subaward monitoring review and certification for 2020 was performed retroactively in 2023. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI has a compliant subrecipient monitoring policy which outlines duties and responsibilities for existing roles covered by CUAHSI staff (primarily, Director of Finance, Accountant, and Principal Investigator). CUAHSI began documenting subrecipient monitoring progress of active awards in May of 2023 and established an updated process on September 21, 2023. CUAHSI Management ensure staff are following these policies via a mid-year process review that verifies documentation is complete, adequate, and is stored securely in an organized manner. Name of Contact Person: 􀁸 Jordan S Read, Executive Director 􀁸 Telephone: (339)933-4660 􀁸 Email: jread@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2019-002

About Subrecipient Monitoring →
2020-006
Cash Management
REPEATMATERIAL WEAKNESS
Condition

MW2020-006 CASH MANAGEMENT (REPEAT FINDING) (PREVIOUSLY REPORTED AS MW2019- 003) Condition The cash management process requires that cash draws be reviewed and approved to ensure the propriety of draw reimbursement requests. Management was unable to provide the auditor evidence documenting approval of the drawdowns for the year ended December 31, 2019. Criteria 2 CFR Part 200 states that entities expending federal grants must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the Federal award. To comply with 2 CFR Part 200, it is required to submit monthly invoices for the funds received under the federal contract. These invoices will serve as a record of the services or goods provided during the specified period and will facilitate accurate tracking and reporting of the funds. In addition to the invoice, any supporting documentation, such as timesheets, should be maintained with the invoices. The cash management process should also be adjusted for the receipt of program income. These documents validate the services provided and ensure transparency and auditability of the invoiced amount. These amounts should be able to be traced to the general ledger in conjunction with the time in which they are billed. Effect Grant awards and reimbursements may not be recorded correctly and there is a higher risk of error or misappropriation of assets.Cause CUAHSI had no fiscal management team during the year ended December 31, 2019, and that all the books and records for that year had to be recreated from bank statements by and outside bookkeeping company years after the fact. Recommendation The auditor recommends CUAHSI develop and implement controls to ensure an adequate review process is in place for review of reimbursement requests submitted to granting agencies to ensure consistent reporting. Current Year Status This condition still exists for the year ended December 31, 2020. During the completion of the audit procedures, the auditor noted that CUAHSI failed to maintain and provide the proper records and support to reconcile the federal award reimbursements and document their review and approval process for the year ended December 31, 2020. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2020: CUAHSI was unable to produce any documentation substantiating specific expenses behind numerous cash draws from NSF during audit year 2020. Corrective actions to processes and responsibilities impacting subsequent years: As of June 15th, 2023, all CUAHSI draws from NSF awards include supporting documents for expenses and a certified SF-270. The SF-270 and documents are stored in a secure and organized document management system. Per CUAHSI’s updated policies, each draw follows segregation of duties and an internal review, approval, and certification process. CUAHSI’s Operations and Program Assistant reviews documents quarterly to ensure all certified draw requests are filed along with associated backup and reports status to Management and relevant CUAHSI Officers (e.g., Treasurer) to ensure policy adherence. Name of Contact Person: 􀁸 Maureen S. Ako, Director of Finance 􀁸 Telephone: (339)221-5400 􀁸 Email: msabino@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2019-003

About Cash Management →
2020-006
Cash Management
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure & Integrative Activities AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099 (09/01/2020 – 08/31/2021) Pass Through Entity: Utah State University & University of Cincinnati MW2020-006 CASH MANAGEMENT Criteria 2 CFR Part 200 states that entities expending federal grants must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the Federal award. To comply with 2 CFR Part 200, CUAHSI was required to submit monthly invoices for the funds received under the federal contract. These invoices will serve as a record of the services or goods provided during the specified period and will facilitate accurate tracking and reporting of the funds. In addition to the invoice, any supporting documentation, such as timesheets, should be maintained with the invoices. The cash management process should also be adjusted for the receipt of program income. These documents validate the services provided and ensure transparency and auditability of the invoiced amount. These amounts should be able to be traced to the general ledger in conjunction with the time in which they are billed. Condition The cash management process requires that cash draws be reviewed and approved to ensure the propriety of draw reimbursement requests. Management was unable to provide the auditor evidence documenting approval of the drawdowns for the year ended December 31, 2020. Cause & Context CUAHSI had no fiscal management team during the year ended December 31, 2020 to ensure compliance with proper policies and procedures. The books and records for the year ended December 31, 2020 were recreated by the current management team during 2023 to 2024. Effect Grant awards and reimbursements may not be recorded correctly and there is a higher risk of error or misappropriation of assets. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2019-003. Recommendation The auditor recommends CUAHSI develop and implement controls to ensure an adequate review process is in place for review of reimbursement requests submitted to granting agencies to ensure consistent reporting. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Finding Reference Number: MW2020-006 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2020: CUAHSI was unable to produce any documentation substantiating specific expenses behind numerous cash draws from NSF during audit year 2020. Corrective actions to processes and responsibilities impacting subsequent years: As of June 15th, 2023, all CUAHSI draws from NSF awards include supporting documents for expenses and a certified SF-270. The SF-270 and documents are stored in a secure and organized document management system. Per CUAHSI’s updated policies, each draw follows segregation of duties and an internal review, approval, and certification process. CUAHSI’s Operations and Program Assistant reviews documents quarterly to ensure all certified draw requests are filed along with associated backup and reports status to Management and relevant CUAHSI Officers (e.g., Treasurer) to ensure policy adherence. Name of Contact Person: 􀁸 Maureen S. Ako, Director of Finance 􀁸 Telephone: (339)221-5400 􀁸 Email: msabino@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2019-003

About Cash Management →
2020-007
Procurement & Suspension/Debarment
REPEATMATERIAL WEAKNESS
Condition

MW2020-007 PROCUREMENT, SUSPENSION AND DEBARMENT (REPEAT FINDING) (PREVIOUSLY REPORTED AS MW2019-004) Condition CUAHSI had a policy in place regarding procurement of which they were unable to provide any documentation that they complied with the policy. There was no documentation for one payment made to the Board Member for $15,000. While there were invoices for the remaining amounts, there was no documentation maintained that showed CUAHSI verified expenses were incurred from vendors that were not suspended or debarred. Criteria The requirements for this compliance requirement are contained in 2 CFR sections 200.317- 200.326; 48 CFR parts 03, 15, 44, and the clauses at 48 CRF sections 52.244-2, 52.244-5, 52.203-13, 52.203-16 and 52.215-12; agency FAR supplements; 2 CFR part 180; OMB M-18- 18; and the terms and conditions of the federal award. There is a requirement to verify that contractors in covered transactions or any of its vendors are not federally debarred, suspended, or excluded. Cause CUAHSI has a policy in place to meet the procurement requirements but there was no evidence of compliance with that policy. Effect CUAHSI is not in compliance with UG requirements, there could be future legal action, the repayment of funds, loss of reputation and possible suspension or debarment.Recommendation It is recommended that CUAHSI strive to prioritize compliance. CUAHSI should ensure that, to the extent practicable, the use of a competitive procurement process in compliance with 2 CFR section 200/317. Current Year Status This condition still exists for the year ended December 31, 2020. During the completion of the audit, the auditor noted that CUAHSI failed to maintain and provide the proper records and support to document their review of vendor files. Such failure led to non-compliance with the procurement, suspension and debarment policies in accordance with the UG for the year ended December 31, 2020. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2020: NA Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI considers the finding to be closed as current practices are compliant and adhere to appropriate policies and procedures. When vendors are onboarded by CUAHSI, a check on disbarment is required and the CUAHSI Director of Finance performs this verification. New procurement requirements were added to CUAHSI policies in 2024 to clarify thresholds and processes for competitive procurement. Also in 2024, an approval certification step was added for all outgoing vendor payments, requiring a monthly certification by the Director of Finance or Executive Director to ensure those receiving payments from CUAHSI are not suspended or disbarred. Name of Contact Person: 􀁸 Maureen S. Ako, Director of Finance 􀁸 Telephone: (339)221-5400 􀁸 Email: msabino@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2019-004

About Procurement and Suspension and Debarment →
2020-007
Procurement & Suspension/Debarment
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure & Integrative Activities AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099 (09/01/2020 – 08/31/2021) Pass Through Entity: Utah State University & University of Cincinnati MW2020-007 PROCUREMENT, SUSPENSION AND DEBARMENT Criteria The requirements for this compliance requirement are contained in 2 CFR sections 200.317- 200.326; 48 CFR parts 03, 15, 44, and the clauses at 48 CRF sections 52.244-2, 52.244-5, 52.203-13, 52.203-16 and 52.215-12; agency FAR supplements; 2 CFR part 180; OMB M-18-18; and the terms and conditions of the federal award. There is a requirement to verify that contractors in covered transactions or any of its vendors are not federally debarred, suspended, or excluded. A covered transaction is a nonprocurement or procurement transaction in excess of $25,000 that is subject to the prohibitions noted in 2 CFR part 180. The covered transaction may be at the primary tier, between a federal agency and a person or a lower tier between a participant in a covered transaction and another person. Condition During the completion of the audit, the auditor noted that CUAHSI failed to maintain and provide the proper records and support to document their review of vendor files for covered transactions. Such failure led to non-compliance with the procurement, suspension and debarment policies in accordance with the UG for the year ended December 31, 2020. CUAHSI did not complete the verification of its 2020 vendors until 2024. Based on our testing, no contractors in covered transactions were deemed to be federally debarred, suspended or excluded. Cause & Context CUAHSI has a policy in place to meet the procurement requirements but there was no evidence of compliance with that policy. Effect As a result of noncompliance, there could be possible repayment of funds, loss of reputation and possible suspension or debarment. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2019-004. Recommendation It is recommended that CUAHSI strive to prioritize compliance. CUAHSI should ensure that, to the extent practicable, the use of a competitive procurement process in compliance with 2 CFR section 200/317. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Finding Reference Number: MW2020-007 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2020: NA Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI considers the finding to be closed as current practices are compliant and adhere to appropriate policies and procedures. When vendors are onboarded by CUAHSI, a check on disbarment is required and the CUAHSI Director of Finance performs this verification. New procurement requirements were added to CUAHSI policies in 2024 to clarify thresholds and processes for competitive procurement. Also in 2024, an approval certification step was added for all outgoing vendor payments, requiring a monthly certification by the Director of Finance or Executive Director to ensure those receiving payments from CUAHSI are not suspended or disbarred. Name of Contact Person: 􀁸 Maureen S. Ako, Director of Finance 􀁸 Telephone: (339)221-5400 􀁸 Email: msabino@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2019-004

About Procurement and Suspension and Debarment →
2020-008
Cash Management
REPEATMATERIAL WEAKNESS
Condition

MW2020-008 FEDERAL DRAWDOWNS IN ADVANCE OF EXPENDITURES (REPEAT FINDING) (PREVIOUSLY REPORTED AS MW2019-009) Condition Subsequent to the year ended December 31, 2019, CUAHSI drew down approximately $1,300,000 from National Science Foundation (“NSF”) based on information that there was going to be a government shutdown. Federal funds are required to be to be drawn down on a reimbursement basis and not in advance of the expenditures. The funds were not returned to NSF after it became clear that there would not be a government shutdown. Criteria CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the management of cash drawdowns and disbursements of federal funds. Federal funds should be disbursed in a timely manner for allowable costs that have been incurred. Cause CUAHSI had insufficient funds available to “float” operating expenses. Effect Drawing down funds in advance of incurring eligible expenses could lead to non-compliance with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need to repay the funds, potential financial penalties, or disqualification from future federal funding.Recommendation The auditor recommends that CUAHSI develops and implements controls over policies consistent with 2 CFR 200.35. Current Year Status This condition still exists for the year ended December 31, 2020. During the completion of the audit, the auditor noted that during 2020, CUAHSI had advance drawdowns totaling $3,610,240 from the NSF. Of this amount, CUAHSI incurred $2,521,926 in eligible expenses for the year ended December 31, 2020. This resulted in $1,088,314 in federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2020 is reported as part of deferred revenue in the accompanying Statement of Financial Position. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2020: All advance draws in 2020 were properly recorded as deferred revenue in the accounting books, see Statement of Financial Position. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI consider this finding resolved. As covered in the corrective action to MW2020-006, CUAHSI implemented the drawdown procedure as documented in company policy which includes twotiered preparation and review and requires review and approval by the Prime funder for working capital advances. CUAHSI stopped the non-compliance in 2023 by halting all draws against NSF awards in late March 2023 (when this non-compliance became known to the current Executive Director) until June 15th, 2023, at which time CUAHSI completed a draw from an NSF aligned with the current policies. The certified SF-270 and draw documentation was reviewed and approved by NSF. Name of Contact Person: 􀁸 Jordan S Read, Executive Director 􀁸 Telephone: (339)933-4660 􀁸 Email: jread@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2019-009

About Cash Management →
2020-008
Cash Management
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure & Integrative Activities AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099 (09/01/2020 – 08/31/2021) Pass Through Entity: Utah State University & University of Cincinnati MW2020-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF EXPENDITURES Criteria CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the management of cash drawdowns and disbursements of federal funds. Federal funds should be disbursed in a timely manner for allowable costs that have been incurred. Cash advances must meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation. Condition CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation which details the requirements for advance fundings. During 2020, CUAHSI had advance drawdowns totaling $3,610,240 from the NSF. Of this amount, CUAHSI incurred $2,521,926 in eligible expenses for the year ended December 31, 2020. This resulted in $1,088,314 in excess federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2020 are reported as part of deferred revenue in the accompanying Statement of Financial Position. Cause & Context In anticipation of a government shut down due to COVID-19, CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter VIII.C.3 of the grant agreement. Effect Drawing down funds in advance of incurring eligible expenses could lead to non-compliance with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need to repay the funds, potential financial penalties, or disqualification from future federal funding. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2019-009. Recommendation The auditor recommends that CUAHSI develops and implements controls over policies consistent with 2 CFR 200.35. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Finding Reference Number: MW2020-08 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2020: All advance draws in 2020 were properly recorded as deferred revenue in the accounting books, see Statement of Financial Position. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI consider this finding resolved. As covered in the corrective action to MW2020-006, CUAHSI implemented the drawdown procedure as documented in company policy which includes twotiered preparation and review and requires review and approval by the Prime funder for working capital advances. CUAHSI stopped the non-compliance in 2023 by halting all draws against NSF awards in late March 2023 (when this non-compliance became known to the current Executive Director) until June 15th, 2023, at which time CUAHSI completed a draw from an NSF aligned with the current policies. The certified SF-270 and draw documentation was reviewed and approved by NSF. Name of Contact Person: 􀁸 Jordan S Read, Executive Director 􀁸 Telephone: (339)933-4660 􀁸 Email: jread@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2019-009

About Cash Management →
2020-009
Program Income
REPEATMATERIAL WEAKNESS
Condition

MW2020-009 PROGRAM INCOME (REPEAT FINDING) (PREVIOUSLY REPORTED AS MW2019- 011) Condition The use of program income generated through a federally funded program will be governed by the terms and conditions of the federal grant award, or sub-award, are subject to the same allowability requirements in 2 CFR 200 for same award objectives and the regulations at 2 CFR 200.307. Program income is defined as “Gross income earned by the recipient that is directly generated by a supported activity or earned as a result of the federal award during the period of performance” by 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards. Program income consists of registration fees collected for training, meetings or workshops and the proceeds from the sale of publications as a result of the federal award during the period of performance. Program income is treated as an additive to the federal funds received by CUAHSI. During a drawdown, program income reduces the amount that is requested to cover reimbursable costs through the Flexible Billing module. This allows program income to be applied to the award before a reimbursement is requested from NSF adding the value of program income received to the awarded amount. Program income reporting is due annually on November 15th. NSF requires that all cumulative program income is reported for all open grants and agreements in the current year. CUAHSI recorded $293,591 of program income for the year ended December 31, 2019. This amount should have been deducted from the grant drawdowns for the year ended December 31, 2019 in accordance with the criteria listed above. There was no audit evidence to support whether the grant revenue was adjusted on the drawdowns. These matters warrant resolution as they may have subsequent adverse impacts. They may ultimately need to be addressed by the oversight agencies. Criteria Pursuant to 2 CFR 200 for award objectives and the regulations at 2 CFR 200.307, program income is defined as “Gross income earned by the recipient that is directly generated by a supported activity or earned as a result of the federal award during the period of performance” by 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards.Criteria (continued) CUAHSI lacked comprehensive documentation demonstrating the proper authorization, allocation, and approval processes for the utilization of program income. 2 CFR 200.307 mandates that clear documentation be maintained to support the proper allocation of program income and its alignment with the program's goals. The non-compliance with program income regulations, as outlined in this finding, highlights the need for corrective action to align CUAHSI’s practices with the stipulated regulations. Management's commitment to addressing these issues will play a pivotal role in rectifying the deficiencies identified during the audit. Effect This is a violation of the terms and conditions of the federal contract with the NSF. Noncompliance can lead to penalties, fines, or even termination of the contract. It may also damage CUAHSI’s reputation and future eligibility for federal funding and jeopardize CUAHSI’s ability to secure future grants or contracts from other funding agencies. Granting organizations typically prioritize funding recipients with a track record of compliance and accountability. Cause Lack of resources and detailed attention to the risks, along with circumvention of controls has resulted in weak internal controls, and conflicting or incomplete policies and procedures. Recommendation The auditor recommends that CUAHSI develops and implements controls over policies consistent with 2 CFR 200.307.Current Year Status This condition still exists for the year ended December 31, 2020. During the completion of the audit, the auditor noted that CUAHSI failed to submit the required Program Income Reporting Worksheet by the required deadline of forty five (45) days after the end of the year to ensure with the program income policies in accordance with the UG for the year ended December 31, 2020. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2020: CUAHSI uses a single payment gateway for registration on CUAHSI events and was able to accurately document and produce grant-specific totals for audit year 2020 program income. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI uses a single payment gateway to segregate payments appropriately per event and per grant. Program income for subsequent years has been reported to NSF annually and appropriate staff and policies are in place to ensure future compliance. Name of Contact Person: 􀁸 Maureen S. Ako, Director of Finance 􀁸 Telephone: (339)221-5400 􀁸 Email: msabino@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2019-011

About Program Income →
2020-009
Program Income
REPEATMATERIAL WEAKNESS
Condition

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure & Integrative Activities AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099 (09/01/2020 – 08/31/2021) Pass Through Entity: Utah State University & University of Cincinnati MW2020-009 PROGRAM INCOME Criteria Pursuant to 2 CFR 200 for award objectives and the regulations at 2 CFR 200.307, program income is defined as “Gross income earned by the recipient that is directly generated by a supported activity or earned as a result of the federal award during the period of performance” by 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards. Program income reporting is due forty five (45) days after the end of the year. NSF requires that all cumulative program income is reported for all open grants and agreements in the current year. Condition Program income consists of registration fees collected for training, meetings or workshops and the proceeds from the sale of publications as a result of the federal award during the period of performance. Program income is treated as an additive to the federal funds received by CUAHSI. During a drawdown, program income reduces the amount that is requested to cover reimbursable costs through the Flexible Billing module. This allows program income to be applied to the award before a reimbursement is requested from NSF adding the value of program income received to the awarded amount. Program income reporting is due forty five (45) days after the end of the year. NSF requires that all cumulative program income is reported for all open grants and agreements in the current year. CUAHSI program income totaled $85,267 for the year ended December 31, 2020. CUAHSI failed to submit the required Program Income Reporting Worksheet by the required deadline of forty five (45) days after the end of the year (February 15, 2021) to ensure with the program income policies in accordance with the UG for the year ended December 31, 2020. Cause & Context Lack of resources and detailed attention to the risks, along with circumvention of controls has resulted in weak internal controls, and conflicting or incomplete policies and procedures. Effect Non-compliance can lead to penalties, fines, or even termination of the contract. It may also damage CUAHSI’s reputation and future eligibility for federal funding and jeopardize CUAHSI’s ability to secure future grants or contracts from other funding agencies. Granting organizations typically prioritize funding recipients with a track record of compliance and accountability. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2019-011. Recommendation The auditor recommends that CUAHSI develops and implements controls over policies consistent with 2 CFR 200.307. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Corrective Action Plan

Finding Reference Number: MW2020-009 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2020: CUAHSI uses a single payment gateway for registration on CUAHSI events and was able to accurately document and produce grant-specific totals for audit year 2020 program income. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI uses a single payment gateway to segregate payments appropriately per event and per grant. Program income for subsequent years has been reported to NSF annually and appropriate staff and policies are in place to ensure future compliance. Name of Contact Person: 􀁸 Maureen S. Ako, Director of Finance 􀁸 Telephone: (339)221-5400 􀁸 Email: msabino@cuahsi.org Projected Completion Date: NA; is complete

Prior Finding References

2019-011

About Program Income →

FY 2019-12-31

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, which was (750 days ago).

What is a management decision? →
2019-001
Cash Management
MATERIAL WEAKNESS
Condition

Current management concurred with the conditions, criteria, causes, and recommendations cited by the auditors. Having to reconstruct the books and transitioning into a new Accounting System; Dynamics 365 was transitioned to Sage Intacct from 2019 forward in order to implement an auditable grant management system and an improved internal control system. In this process, the detailed reconciliations may have been abandoned in the older accounting system. The transition of new management in early 2023 has now implemented these internal control systems and monthly reconciliations from 2022 and forward in order to comply with 2 CFR 200 and NSF requirements.

Corrective Action Plan

Current management concurred with the conditions, criteria, causes, and recommendations cited by the auditors. Having to reconstruct the books and transitioning into a new Accounting System; Dynamics 365 was transitioned to Sage Intacct from 2019 forward in order to implement an auditable grant management system and an improved internal control system. In this process, the detailed reconciliations may have been abandoned in the older accounting system. The transition of new management in early 2023 has now implemented these internal control systems and monthly reconciliations from 2022 and forward in order to comply with 2 CFR 200 and NSF requirements.

About Cash Management →
2019-001
Cash Management
MATERIAL WEAKNESS
Condition

Current management concurred with the conditions, criteria, causes, and recommendations cited by the auditors. Having to reconstruct the books and transitioning into a new Accounting System; Dynamics 365 was transitioned to Sage Intacct from 2019 forward in order to implement an auditable grant management system and an improved internal control system. In this process, the detailed reconciliations may have been abandoned in the older accounting system. The transition of new management in early 2023 has now implemented these internal control systems and monthly reconciliations from 2022 and forward in order to comply with 2 CFR 200 and NSF requirements.

Corrective Action Plan

A required monthly bank reconciliation is performed by the CUAHSI accountant with oversight from the CUAHSI Controller or more senior finance role (e.g., CFO or Director of Finance). This practice is in place.

About Cash Management →
2019-002
Subrecipient Monitoring
MATERIAL WEAKNESS
Condition

CUAHSI's Federal Grant Management Policies and Procedures updated in February 2019 was not implemented and followed for calendar year 2019. In light of this finding, current management is reviewing the current Federal Grant Management Policies and Procedures along with Subrecipient Risk Assessment internally developed for financial and compliance monitoring in order to update and implement the regulatory required reporting and documentation moving forward.

Corrective Action Plan

CUAHSI's Federal Grant Management Policies and Procedures updated in February 2019 was not implemented and followed for calendar year 2019. In light of this finding, current management is reviewing the current Federal Grant Management Policies and Procedures along with Subrecipient Risk Assessment internally developed for financial and compliance monitoring in order to update and implement the regulatory required reporting and documentation moving forward.

About Subrecipient Monitoring →
2019-002
Subrecipient Monitoring
MATERIAL WEAKNESS
Condition

CUAHSI's Federal Grant Management Policies and Procedures updated in February 2019 was not implemented and followed for calendar year 2019. In light of this finding, current management is reviewing the current Federal Grant Management Policies and Procedures along with Subrecipient Risk Assessment internally developed for financial and compliance monitoring in order to update and implement the regulatory required reporting and documentation moving forward.

Corrective Action Plan

CUAHSI has a compliant subrecipient monitoring procedure in our Federal Grant Management Policies and Procedures Manual which applies to various existing roles covered by CUAHSI staff (Controller, Accountant, PI). CUAHSI began documenting subrecipient monitoring progress of active awards in May of 2023 and established updated processes on September 21, 2023. CUAHSI management will ensure staff are following these policies by instituting yearly process reviews that verify process documentation is stored securely in an organized manner and subrecipient monitoring is being performed adequately per Federal award terms and conditions, 2 CFR 200.300, .330, .331, and .501(h). CUAHSI Management will evaluate current job descriptions and performance criteria to make sure duties and responsibilities are aligned with the policies and procedures manual.

About Subrecipient Monitoring →
2019-003
Cash Management
MATERIAL WEAKNESS
Condition

Processes have now been implemented by new management to require Form SF-270 with source documentation backup for every drawdown submitted to the National Science Foundation.

Corrective Action Plan

Processes have now been implemented by new management to require Form SF-270 with source documentation backup for every drawdown submitted to the National Science Foundation.

About Cash Management →
2019-003
Cash Management
MATERIAL WEAKNESS
Condition

Processes have now been implemented by new management to require Form SF-270 with source documentation backup for every drawdown submitted to the National Science Foundation.

Corrective Action Plan

CUAHSI has resolved this issue by halting all draws against NSF awards in late March 2023 (when this non-compliance became known to the current Executive Director) until June 15th, 2023, when CUAHSI completed a draw from an NSF award after supporting documents for expenses were submitted with a certified SF-270 to be reviewed and approved by NSF. The SF-270 and backup documents were saved in a single secure document location and filed accordingly. This procedure has been followed since the June 2023 draw; related drawdown procedures in our Federal Grant Management Policies and Procedures Manual have been adhered to as well. Each draws follow segregation of duties and an internal approval process. In once-yearly financial reviews (off-season with required single audits), process documentation will be reviewed by Management and relevant CUAHSI Officers (e.g., Treasurer) to ensure policy adherence.

About Cash Management →
2019-004
Procurement & Suspension/Debarment
MATERIAL WEAKNESS
Condition

Documentation in the present accounting system has not been maintained that verify contractors are not federally debarred, suspended, or excluded. A vendor onboarding process is currently being developed to address vendor verification and risk assessment.

Corrective Action Plan

Documentation in the present accounting system has not been maintained that verify contractors are not federally debarred, suspended, or excluded. A vendor onboarding process is currently being developed to address vendor verification and risk assessment.

About Procurement and Suspension and Debarment →
2019-004
Procurement & Suspension/Debarment
MATERIAL WEAKNESS
Condition

Documentation in the present accounting system has not been maintained that verify contractors are not federally debarred, suspended, or excluded. A vendor onboarding process is currently being developed to address vendor verification and risk assessment.

Corrective Action Plan

CUAHSI considers the finding to be closed as current practices are compliant and adhere to CUAHSI policies and procedures. When vendors are onboarded by CUAHSI, the Federal Grant Management Policies and Procedures Manual states that a check on disbarment is required and the CUAHSI Controller performs this verification. This manual was in place during the audit year there was no documentation available to assure it was being followed. Beginning in 2024, process documentation will be reviewed by Management and relevant CUAHSI Officers (e.g., Treasurer) during yearly reviews to ensure policy adherence.

About Procurement and Suspension and Debarment →
2019-005
Cost Allowability
MATERIAL WEAKNESS
Condition

Newly established retention and control of source documents has been implemented with new 2023 management within the accounting system providing source documentation for unlimited retention of source documentation to remedy the 4% inadequately documented transactions in this test pool.

Corrective Action Plan

Newly established retention and control of source documents has been implemented with new 2023 management within the accounting system providing source documentation for unlimited retention of source documentation to remedy the 4% inadequately documented transactions in this test pool.

About Allowable Costs / Cost Principles →
2019-005
Cost Allowability
MATERIAL WEAKNESSQUESTIONED COSTS
Condition

Newly established retention and control of source documents has been implemented with new 2023 management within the accounting system providing source documentation for unlimited retention of source documentation to remedy the 4% inadequately documented transactions in this test pool.

Corrective Action Plan

In May 2023, CUAHSI addressed this finding by maintaining all expense backup in a centralized accounting system (Sage Intaact) where two-tier review and approvals are captured with an audit trail. For the fiscal years prior to this process change (including this audit year, 2019), CUAHSI has exported emails and prior finance staff documentation in a secure and searchable archive. At the time of auditor requests for expense documentation of these questioned costs, this archive was incomplete and missing exports from prior in-office local storage hard drive that was utilized by prior accounting staff. In December of 2023, a more comprehensive version of the archive was used to establish documentation for cost principle adherence for all expenses included in the reported $11,325 of questioned costs (see details below, full documentation available via email).

About Allowable Costs / Cost Principles →
2019-006
Reporting
MATERIAL WEAKNESS
Condition

Update: This finding has been corrected as a result of the opinion on the SEFA at the beginning of this report.

Corrective Action Plan

Documentation due to flat draws and invoicing have prohibited the information and audit trail necessary for the preparation of the 2019 SEFA. In addition, processes and procedures are currently being established as a result of newly issued NSF corrective actions that have also identified deficiencies in the organization's ability establish proper invoicing guidelines to document and track federal award expenditures along with exclusions and unallowable costs for future preparation of this document. New management brought on board in 2023 lacked some key details of prior years to properly provide this document in the timeframe required by auditors. This will be rectified and new workforce and training strategies that address the knowledge deficiencies for 2 CFR Part 200 will help establish future processes and procedures and work the SEFA details into our operational accounting system so future construction of the SEFA is simplified and likelihood of errors reduced.

About Reporting →
2019-006
Reporting
MATERIAL WEAKNESS
Condition

Subsequent to year end of the audit period, CUAHSI replaced the contracted external finance team with two full-time CUAHSI employees and one part-time employee (these staff were hired in September and October of 2023). After this personnel change, CUAHSI was able to produce a SEFA (sent to the auditors via email December 4th, 2023).

Corrective Action Plan

We consider this finding to be addressed with the replacement of contract staff with new CUAHSI employees (as of September, 2023) with the skills, knowledge, and experience to support single audit preparation. CUAHSI had engaged with an external contract financial team that failed to complete necessary preparation for the required 2019 single audit, including the preparation of an accurate SEFA. Subsequent to year end of the audit period, CUAHSI replaced the contracted external finance team with two full-time CUAHSI employees and one part-time employee (these staff were hired in September and October of 2023). After this personnel change, CUAHSI was able to produce a SEFA (sent to the auditors via email December 4th, 2023) of which the auditor could render an opinion for the year ended 2019.

About Reporting →
2019-007
Reporting
MATERIAL WEAKNESS
Condition

2.Commonwealth of Massachusetts Attorney General’s Office Non-Profit Division – Registration andfilings of PC for the purposes of retaining non-profit status Certificate of Good Standing.

Corrective Action Plan

New management will be augmenting the workforce with staff and training to address 2 CFR Part 200 compliance that will assist with NSF IDC Rate Proposal submission track record and direct relationship with NSF to review processes, procedures and assist with the review, required submission and reporting to the following entities:

About Reporting →
2019-007
Reporting
REPEATMATERIAL WEAKNESS
Condition

2.Commonwealth of Massachusetts Attorney General’s Office Non-Profit Division – Registration andfilings of PC for the purposes of retaining non-profit status Certificate of Good Standing.

Corrective Action Plan

CUAHSI has outstanding audits for the years ended 2020, 2021, 2022, and 2023. This will be a repeat finding until after the 2023 audit is completed. This recurring issue is being addressed as new CUAHSI management was hired in January of 2023 and the top priority of the Executive Director, finance team, and the Board of Directors is to ensure CUAHSI is able to address this unacceptable recurring finding. CUAHSI's new financial staff, new within-year processes to ensure policies are followed and staff are accountable, along with replacing the accounting system of record with a centralized and robust solution (transition completed) will make audit preparation routine in future years. In January 2024, the CUAHSI Board voted in a new Treasurer with 18 years of audit experience; this is the first time the Treasurer role has been occupied by a non-hydrologist (the primary scientific discipline that CUAHSI’s mission serves).

Prior Finding References

2018-001

About Reporting →
2019-008
Reporting
MATERIAL WEAKNESS
Condition

Prior source information coupled with flat drawdowns resulting in the lack of issued invoices were not available in reconstructing the books required in providing accurate allocation of real-time activities. Input of documentation was done directly from the organization's bank statements which does not reflect proper allocation. Future policy has been rectified to designate cost pools, dimensions and grant allocation with source documentation verified and included as backup in the new accounting system.

Corrective Action Plan

Prior source information coupled with flat drawdowns resulting in the lack of issued invoices were not available in reconstructing the books required in providing accurate allocation of real-time activities. Input of documentation was done directly from the organization's bank statements which does not reflect proper allocation. Future policy has been rectified to designate cost pools, dimensions and grant allocation with source documentation verified and included as backup in the new accounting system.

About Reporting →
2019-008
Reporting
MATERIAL WEAKNESS
Condition

Prior source information coupled with flat drawdowns resulting in the lack of issued invoices were not available in reconstructing the books required in providing accurate allocation of real-time activities. Input of documentation was done directly from the organization's bank statements which does not reflect proper allocation. Future policy has been rectified to designate cost pools, dimensions and grant allocation with source documentation verified and included as backup in the new accounting system.

Corrective Action Plan

We consider this finding to be addressed with the replacement of contract staff with new CUAHSI employees (as of September, 2023) with the skills, knowledge, and experience to support functional expense allocation. Expenses are reviewed and proper assignment to appropriate grants and accounting codes is ensured with a two-tier review.

About Reporting →
2019-009
Special Tests & Provisions
MATERIAL WEAKNESS
Condition

2019 Management retained the funds in lieu of redeposit resulting in the ACM$ drawdown being halted for the impacted award for 10 months before resuming draw downs. New 2023 Management has put internal controls in place with SF-270 submission for all drawdowns and source backup for all allowable expenses and procedures to ensure 2 CFR Part 200.305 compliance.

Corrective Action Plan

2019 Management retained the funds in lieu of redeposit resulting in the ACM$ drawdown being halted for the impacted award for 10 months before resuming draw downs. New 2023 Management has put internal controls in place with SF-270 submission for all drawdowns and source backup for all allowable expenses and procedures to ensure 2 CFR Part 200.305 compliance.

About Special Tests and Provisions →
2019-009
Cash Management
MATERIAL WEAKNESS
Condition

2019 Management retained the funds in lieu of redeposit resulting in the ACM$ drawdown being halted for the impacted award for 10 months before resuming draw downs. New 2023 Management has put internal controls in place with SF-270 submission for all drawdowns and source backup for all allowable expenses and procedures to ensure 2 CFR Part 200.305 compliance.

Corrective Action Plan

CUAHSI consider this finding resolved. A deferred income entry of $1.233M from September 24th, 2020 was shared by the auditors with CUAHSI's current Executive Director on June 19th, 2023 and CUAHSI immediately investigated what had transpired, discovering an advanced draw was performed by prior CUAHSI staff. This information was immediately shared with the auditors. During the week of June 26th, 2023, the non-compliance was reported to the Executive Committee of the Board of Directors and shared verbally with NSF, and separately with three other NSF employees during a virtual meeting on July 14th, 2023. The non-compliance was shared more widely with additional NSF staff in writing on August 8th, 2023. As covered in the corrective action to 2019-003, CUAHSI implemented the drawdown procedure as documented in CUAHSI's Federal Grant Management Policies and Procedures Manual with two-tiered preparation and review to ensure approval is obtained from the Prime funder for working capital advances. CUAHSI also completed a return of funds from two approved advances drawn on September 25th, 2023 within a reasonable timeframe (October 10, 2023 for the first payment and November 27th, 2023 for the second payment).

About Cash Management →
2019-010
Special Tests & Provisions
MATERIAL WEAKNESS
Condition

The Executive Committee has been informed by Management of all deficiencies for accountability. The reporting of all accounting and internal controls weaknesses is being reviewed and will be remedied with the approval of the Board and newly established Audit Committee.

Corrective Action Plan

The Executive Committee has been informed by Management of all deficiencies for accountability. The reporting of all accounting and internal controls weaknesses is being reviewed and will be remedied with the approval of the Board and newly established Audit Committee.

About Special Tests and Provisions →
2019-010
Special Tests & Provisions
MATERIAL WEAKNESS
Condition

The Executive Committee has been informed by Management of all deficiencies for accountability. The reporting of all accounting and internal controls weaknesses is being reviewed and will be remedied with the approval of the Board and newly established Audit Committee.

Corrective Action Plan

CUAHSI considers this finding partially addressed as new hiring has ensured staff with adequate knowledge are positioned in financial roles. Staffing and separation of duties with multi-tier reviews and approvals supports the roles outlined in CUAHSI's Federal Grant Management Policies and Procedures Manual and a yearly financial process review will ensure policies are being followed. CUAHSI will add bank reconciliation processes to the manual. Currently this is an assigned duty to the Accountant with oversight from the Controller, but is not documented in the manual.

About Special Tests and Provisions →
2019-011
Program Income
MATERIAL WEAKNESS
Condition

Program income of $293,591 was entered into Sage and submitted to the auditor along with all other General Ledger details. Separately, CUAHSI reported program incomes of different (smaller) amounts to NSF that are likely reflective of actual incomes generated by the active awards. Potential mischaracterization in General Ledger detail may have resulted in overstating program income. The organization is working to implement processes that are 2 CFR Part 200.307 compliant and will be work with their cognizant agency to reconcile accurate program income relative to award draws.

Corrective Action Plan

Program income of $293,591 was entered into Sage and submitted to the auditor along with all other General Ledger details. Separately, CUAHSI reported program incomes of different (smaller) amounts to NSF that are likely reflective of actual incomes generated by the active awards. Potential mischaracterization in General Ledger detail may have resulted in overstating program income. The organization is working to implement processes that are 2 CFR Part 200.307 compliant and will be work with their cognizant agency to reconcile accurate program income relative to award draws.

About Program Income →
2019-011
Program Income
MATERIAL WEAKNESS
Condition

Program income of $293,591 was entered into Sage and submitted to the auditor along with all other General Ledger details. Separately, CUAHSI reported program incomes of different (smaller) amounts to NSF that are likely reflective of actual incomes generated by the active awards. Potential mischaracterization in General Ledger detail may have resulted in overstating program income. The organization is working to implement processes that are 2 CFR Part 200.307 compliant and will be work with their cognizant agency to reconcile accurate program income relative to award draws.

Corrective Action Plan

CUAHSI uses a single payment gateway for registration on CUAHSI events, which is the organization’s only source of program income during the audit year (2019) up to present day (February 2024). The CVENT platform segregates events and CUAHSI program staff align these event codes to the grants supporting the events. Though identifiable through the CVENT system, our external contract accounting team failed to record and classify the program income to the correct grant in the accounting books and incorrectly included some grant expense reimbursement revenue in the program income transactions and totals provided to the auditors. Reporting program income to NSF through the annual program income report was not affected and was reported accurately. CUAHSI has addressed this issue by building its financial team and hiring accounting employees (as of September, 2023) with the skills, knowledge, and experience to appropriately manage the finances of federal awards. The new accounting team has applied proper identification of the events and have corrected the misclassification done by the former contractors.

About Program Income →

FY 2018-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on October 20, 2020. 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 April 20, 2021, which was (1948 days ago).

What is a management decision? →
2018-002
Reporting
REPEATMATERIAL WEAKNESS
Condition

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-001

About Reporting →

FY 2017-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on December 12, 2018. 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 12, 2019, which was (2626 days ago).

What is a management decision? →
2017-001
Reporting
REPEATMATERIAL WEAKNESS
Condition

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-001

About Reporting →

FY 2016-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on December 7, 2018. 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 7, 2019, which was (2631 days ago).

What is a management decision? →
2016-001
Reporting
MATERIAL WEAKNESS
Condition

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →

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.

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