WESTERN NEVADA COLLEGE GRANTS AND CONTRACTS Internal Audit Report July 1, 2010 through September 30, 2011

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1 WESTERN NEVADA COLLEGE GRANTS AND CONTRACTS Internal Audit Report July 1, 2010 through September 30, 2011 GENERAL OVERVIEW During the audit period, Western Nevada College (WNC) had 33 active sponsored projects totaling approximately $1.5 million. The awards were issued primarily for educational purposes, such as adult basic education, technology preparation and similar types of programs. The administration of sponsored projects involves various faculty and staff that were involved in soliciting the awards who are referred to as the grant directors. The grant directors are responsible for maintaining an award file and ensuring required documentation is maintained. They are also responsible for completing personnel activity reports (PARs), ensuring expenditures are reasonable and related to the award, submitting required program reports to the sponsors, determining the disposition of equipment purchased with award funds and retaining award files in accordance with accepted standards. The Controller s Office is responsible for accounting related functions including account set-up and closing, vendor invoicing, receipt and deposit of funds and financial reporting. WNC procedures require proposals and applications for sponsored project funding to be reviewed and approved by the college s Grants Review Committee before they are submitted to the granting agency. In addition, all sponsored project applications and contracts are required to be signed by the WNC President or an authorized designee. SCOPE OF AUDIT The Internal Audit Department has completed a review of grants and contracts at WNC for the period of July 1, 2010 through September 30, (AUDIT COMMITTEE 09/06/12) Ref. A-8, Page 1 of 12

2 The scope of our review included tests of the accounting records and other auditing procedures as we considered necessary. The tests included, but were not necessarily limited to, these areas. 1. Reviewing award files for required documentation. 2. Reviewing and testing indirect cost rates. 3. Reviewing and testing subcontract agreements. 4. Testing expenditures for supporting documentation, proper signature approvals, and allowance of costs as stipulated in the Office of Management and Budget (OMB) Circular A Examining billing and reporting requirements. 6. Testing equipment inventory for allowable cost, proper procurement and identification. 7. Reviewing close-out procedures. In our opinion, we can be reasonably assured that the administration of grants and contracts at WNC is being performed in a satisfactory manner. However, implementation of the following recommendations would further improve this process. AWARD DOCUMENTATION A sample of seven awards was selected to determine whether all required documentation was maintained and that each award was approved by the Grants Review Committee. The following exceptions were noted. 1. A Grant Proposal Review Form was not on file for five of the seven awards tested. This form is used by the review committee to document the review and approval process for each proposal. As a result, it does not appear the awards were approved by the college. (AUDIT COMMITTEE 09/06/12) Ref. A-8, Page 2 of 12

3 The Grant Proposal Review Forms are maintained by the committee chair after they have been reviewed by the committee. A copy is not included in the award file or provided to any other party. We recommend greater care be taken to ensure proposals for sponsored project funding are subjected to the college s review and approval process. We also recommend a copy of the Grant Proposal Review Form be forwarded to the appropriate grant director for inclusion in the award file and to the Controller s Office. The Controller s Office should verify an approved form is on file before establishing a sponsored project account in the financial accounting system. Institutional Response: Effective with receipt of the audit, the Grant Review Committee chair will maintain the original, fully executed Grant Proposal Review Form and will provide copies to both the WNC controller and the grant director or principal investigator. 2. Of the two Grant Proposal Review Forms that were on file and reviewed, one was not signed by all required parties. We also noted instances, on both forms, in which some of the signers did not indicate their approval/disapproval of the proposal. We recommend the Grant Proposal Review Form be signed and completed in its entirety. Institutional Response: Effective with receipt of the audit, the Grant Review Committee chair will ensure that the Grant Proposal Review Form is signed and completed in its entirety. Additionally, the Grant Review Committee chair will mark the form Complete and date stamp the form before distributing to the WNC controller and grant director or principal investigator. 3. A Project Data Sheet could not be located for one of the seven awards tested. We also noted six Project Data Sheets were not completed and signed by the Controller s Office, as required. We recommend Project Data Sheets be properly maintained and completed in their entirety. (AUDIT COMMITTEE 09/06/12) Ref. A-8, Page 3 of 12

4 Institutional Response: Effective with receipt of the audit, the WNC controller will ensure that Project Data Sheets are completed in their entirety and will be maintained in the appropriate grant file stored in the controller s office. EFFORT REPORTING WNC procedures require the completion of a Personnel Activity Report (PAR) for each individual who is paid from sponsored project funding. This reporting method is derived from the Office of Management and Budget (OMB) Circular A-21 which requires the above, or other acceptable method, for reporting this information. PARs are required to reflect 100% of an employee s time and must be signed by the employee and a responsible official as verification of the work performed. A sample of nine employees, who were paid from sponsored projects during the audit period, was reviewed to determine whether PARs were completed as required. The following exceptions were noted. 1. PARs were not completed for eight of the nine employees tested. We recommend each grant director be instructed of the requirements for completing PARs. We recommend PARs be brought up to date for all sponsored projects that are currently active. Institutional Response: On an annual basis, the Grant Review Committee chair and the WNC controller will provide an overview of grant procedures to faculty/staff in a workshop-like setting. This workshop will include instruction on how to complete and maintain the PAR form. In addition, the Vice President for Finance and Administrative Services will identify all sponsored projects without current PARs and notify in writing, the relevant directors/principal investigators that all PARs must be current within 30 days of the notification. 2. For one employee, 15 PARs were reviewed. We noted the effort reported on each of the PARs did not equal 100%, as required. On one occasion, the distribution of time exceeded 100%. This was due to the employee s regular faculty appointment and a separate letter of appointment contract being included on one PAR. (AUDIT COMMITTEE 09/06/12) Ref. A-8, Page 4 of 12

5 We recommend the distribution of time reported on PARs equal 100%, as required. We also recommend a separate PAR be completed for each contract for which employees are paid from sponsored awards. Institutional Response: the WNC controller and the Grant Review Committee chair reviewed this issue with the appropriate director. The correct calculation process for the PARs is now understood and will be used for all future PARs. CASH MANAGEMENT Sponsored project awards are typically paid by the granting agencies on a cost reimbursement basis. This means the agencies do not disburse funds until after they receive an invoice from WNC reflecting expenditures incurred by the college. We reviewed all 14 of the invoices that were prepared and submitted to sponsoring agencies during the audit period for the seven awards examined. The invoices, and subsequent reimbursements received, were reviewed for accuracy and for proper posting to the financial accounting system. The following exceptions were noted. 1. While conducting this review, we noted the revenue that was posted to two sponsored project accounts, during fiscal year , exceeded the award amount by $366,626. We were informed the excess revenue was due to reimbursements from fiscal year that were recorded in fiscal year For one of the accounts, we also noted the expenditures posted to the account during fiscal year exceeded the award amount by $17,615. We were informed the difference was due to expenses incurred in fiscal year that were recorded in fiscal year OMB Circular A-110 states recipients of awards must maintain a financial management system that is accurate, current and complete and the records must identify adequately the (AUDIT COMMITTEE 09/06/12) Ref. A-8, Page 5 of 12

6 source and application of funds. We recommend greater care be taken to ensure revenue and expenditure activity is recorded accurately in the financial accounting system. We also recommend the Controller s Office review these accounts to ensure documentation is on file to support the variances noted. Institutional Response: The WNC controller implemented the recording of receivables in FY11, which resulted in the accounting system containing two years of data in one fiscal year. This was a one-time issue. Going forward, the grant accounts will have a year-end receivable recorded, which will ensure that the accounting is accurate, current and complete. Any variances will be documented in the file. 2. On one occasion, the revenue received from a granting agency was posted as a negative expenditure in the financial accounting system. We recommend sponsored project funding be recorded as revenue in the financial accounting system. Institutional Response: All receipts from granting agencies will be correctly recorded as revenue in the financial accounting system. 3. The Controller s Office only monitors awards for invoicing purposes that have a June 30 end date. Awards with different end dates are not monitored. The reason for this is to ensure invoices and receivables are properly accounted for at year end. We recommend the Controller s Office maintain a list of active awards to ensure invoices for awards are issued in a timely manner. Institutional Response: The WNC controller created a spreadsheet to capture all awards. This spreadsheet identifies the award information, date of award, account assigned and whether or not billings have been made against the award. This spreadsheet is reviewed monthly so that granting agencies/organizations are invoiced in a timely manner. (AUDIT COMMITTEE 09/06/12) Ref. A-8, Page 6 of 12

7 CLOSE OUT FORM There are a number of steps that must be performed to close out awards properly. We noted the steps have not been documented to ensure the close out process is complete and is performed in a timely manner. We recommend a close out form be developed to assist in this process. The form should include the steps that are necessary to close out an award. This would include, but not be limited to, verification that program and financial reports were submitted, final invoicing was completed, award and cost share accounts were closed, indirect costs were calculated correctly and equipment and supply inventories were handled properly. We recommend the close out form be completed and signed off by the individuals that performed each of the steps and that the form be maintained in the award file. Institutional Response: Using an identified best practice (DRI close out form) from a sister NSHE institution, the WNC controller developed a close out form that will be signed off by the individuals that perform each of the steps. This form will be maintained in the award file in the WNC controller s office. A copy of the form is attached as Addendum A. EXPENDITURES We reviewed a sample of 35 expenditures that were charged to seven awards selected for review. The transactions were reviewed for proper supporting documentation, approval, reasonableness, and compliance with OMB Circular A-122 requirements. Of the 35 transactions, no exceptions were noted with 31. The following exceptions were noted with the four remaining transactions. 1. On three occasions, expenditures were not approved by an authorized signer for the accounts that were charged. We recommend expenditures be approved by a proper authority. (AUDIT COMMITTEE 09/06/12) Ref. A-8, Page 7 of 12

8 Institutional Response: Business office personnel will ensure that the proper authority approves all expenditures. Additionally, when pro-card reconciliations include a variety of accounts, a proper signature will be obtained for each applicable charge, and then submitted to the supervisor for signature. 2. For one travel claim reviewed, an employee was reimbursed for meals that were included with the conference registration fee. We recommend that greater care be taken to ensure per diem is not paid when meals are provided with the conference registration fee. Institutional Response: The error in the travel claim was corrected, and the traveler reimbursed the account for the appropriate amount. Greater care will be taken to ensure that per diem is not paid when meals are provided as part of a conference or seminar. To accomplish this, conference information and/or itinerary will be required from the reimbursement requestor before paying per diem. INDIRECT COSTS Three of the seven awards reviewed allowed indirect costs to be charged. We noted the indirect cost rate applied for each of the three awards, within the financial accounting system, did not agree with the approved rate that was specified in the award documentation. As a result, the amount of indirect costs charged to the awards was incorrect. We recommend greater care be taken to ensure the correct indirect cost rate is utilized when accounts are established in the financial accounting system. Institutional Response: Effective with receipt of the audit, when a grant allows for indirect costs, the WNC controller will require the grant director or principal investigator to provide proof of the authorized percentage rate. This will then be recalculated and verified against what has been submitted on the Project Data Sheet to ensure that the proper percentage is being used. COST SHARE One of seven awards reviewed contained a matching requirement of $3,051. A matching account was established in the financial accounting system to monitor these funds. We noted there was no activity in the account during the grant period, which was fiscal year We (AUDIT COMMITTEE 09/06/12) Ref. A-8, Page 8 of 12

9 were informed by the Controller s Office that the financial data reflecting the match was posted to another account. OMB Circular A-110 requires cost share to be verifiable from recipients records. We recommend an explanation of the cost share for this project be documented and included in the award file. We also recommend cost share be posted to the account established for this purpose. Institutional Response: The cost share explanation is documented and included in the appropriate grant award file. In addition, the cost share requirements and the financial data representing the match portion have properly been recorded in the match account. Effective with receipt of the audit, any grants that require a cost share will be documented in the grant file. Additionally, this cost share will be posted to the account established for this purpose. REPORTING We reviewed the reporting requirements for each of the seven awards tested and then performed a review to verify whether the reports were completed and submitted to the awarding agencies in a timely manner. For one of the awards, we noted three of four program reports were not submitted by the due date. We recommend reports be submitted in a timely manner. Institutional Response: Timely submission of reports as required is consistent with institutional processes. In this case, illness of the director responsible for these reports prevented them from being completed in a timely manner. The granting agency for the three awards gave approval for the late submission of the reports. EQUIPMENT INVENTORY We noted an equipment item purchased from one of the seven awards reviewed did not have an asset tag attached. We recommend an asset tag be obtained from the Business Center North Purchasing Department and affixed to the equipment. Institutional Response: When the auditors identified this issue, the inventory tag was issued and the equipment tagged. Business office staff responsible for inventory (AUDIT COMMITTEE 09/06/12) Ref. A-8, Page 9 of 12

10 control were reminded of the inventory control process and of the importance of accurate, timely recording of all equipment purchases. GRANT PROCEDURES We reviewed the college s grant procedures, as documented in the WNC Policy Manual, and noted the following areas in which improvements could be made. 1. Cost-share is not addressed in the procedures. 2. A number of close-out procedures are not addressed as noted in this report. 3. The record retention procedures do not include all of the requirements of the OMB Circular A The current effort reporting procedures require PARs to be completed once a semester. TRAINING OMB Circular A-21 states that activity reports for non-professional employees are required to be completed at least once a month. We recommend the grant procedures in the WNC Policy Manual be updated to address items one through four above. Institutional Response: The WNC controller and the Grant Review Committee chair updated the college s current Grant Procedures policy (WNC Policy 7-7-1). The edited policy will be reviewed by the college community, and approved by College Council in the fall semester Additionally, the Grant Review Committee chair will inform potential grant directors about the procedures that must be followed upon awarding of the grant. The draft policy revision is attached as Addendum B. Based on the findings that were noted in this review, we believe WNC personnel who are involved in the administration of sponsored projects are in need of training to enhance their knowledge of this area. The training should include the college s review and approval process, required award documentation, account and file maintenance, effort reporting, equipment (AUDIT COMMITTEE 09/06/12) Ref. A-8, Page 10 of 12

11 purchases, reimbursement requests, indirect costs, cost-sharing, close-out and record retention procedures. We recommend consideration be given for providing training to employees. Institutional Response: Grants administration training is scheduled for Controller C. Lopez and Grants Committee Chair, J. Craig in June A copy of the twoday training session information is attached as Addendum C. This training will be updated periodically. Additionally, the controller and Grant Review Committee chair will facilitate an annual workshop to the college community about grant procedures. SPONSORED PROJECTS ADMINISTRATION As previously mentioned in this report, the administration of sponsored projects at WNC is performed by a variety of employees throughout the college. A centralized function does not exist to help provide support and guidance to the campus community, to assist in the completion, organization, and storage of records and to promote compliance with the various regulatory requirements of sponsored projects. We recommend consideration be given for establishing a centralized sponsored project function at the college. Institutional Response: Controller C. Lopez is appointed as the institutional lead for the WNC sponsored project at the college. The chair of the WNC Grants Committee will support her with these duties. (AUDIT COMMITTEE 09/06/12) Ref. A-8, Page 11 of 12

12 The Internal Audit Department appreciates the cooperation and assistance received from WNC personnel during this review. Reno, Nevada March 23, 2012 Mary S. Stoltz Senior Internal Auditor Eric Wilber Internal Auditor II Scott Anderson Internal Audit Manager Sandra K. Cardinal Assistant Vice Chancellor for Internal Audit (AUDIT COMMITTEE 09/06/12) Ref. A-8, Page 12 of 12

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