BMG Update NSF OIG Audit November 4, 2014 Sandy Moulton, Office of Grants and Contracts

Audit Facts Began in June 7, 2013 Audit Scope – April 1, 2010 through March 31, 2013 First Conference Call – July 3, 2014 Formulation of the Data Team AITS – Mike Neville GCO – Jayne Goby, Amy Roessler and Ruth Boardman See Report at http://www.nsf.gov/oig/reports/14-1-006_UIUC.pdf

Initial Data Request Data Request June 28, 2013 Please provide by July 12, 2013 Download of General Ledger, Subledger, Modules and/or Subsystems (ex:  A/P, Payroll, Labor Effort Reporting) detail for all current period costs claimed on the University’s December 31, 2012 FFR filed with NSF. (one quarter) Reconciliation of the General Ledger data provided in Item #1 to the FFR filed with NSF for the quarter ended December 31, 2012. Reconciliation of the subsystem data provided in Item #1 to the General Ledger.  Control/Hash totals for all files provided.  A data dictionary containing the record layout for each field.

DATA (continued) Crosswalk of NSF Award Identification Numbers to University records, including a listing of all federally funded projects with account numbers and the type of project (research, training, instruction, etc...). Crosswalk of University expenditure accounts to NSF budget categories, including salaries, equipment, participant support, subawards, etc. Detailed query parameters and methodology used to extract all data provided. System architecture, data models, data dictionaries, database schema, and data flowcharts describing the financial system structure and interaction of the University’s financial systems and subsystems (see Attachment). Name and contact information of a database manager or an individual in your Information Technology division or data warehouse whom we can contact directly to discuss our preferred file format and coordinate a suitable timeframe and transmission method for all data submissions.

DATA (continued) Facilities and Administration (F&A) Rate Agreement(s). Chart of accounts including descriptions of cost categories and identification of any specific accounts for accumulating unallowable federal grant costs. University policies and procedures for administrative and financial management of federal grant funds, including accounting manuals, labor effort reporting, cost share, cost transfers, travel, procurement, property management, subawards, consultants, indirect costs, FFR preparation, and American Recovery and Reinvestment Act reporting requirements. Control/hash totals include a record count and sum of numbers that allows us to ensure that we have correctly imported the data into our system. A record layout generally includes the field name, field length, data type, and field description for each field in an information system

Citation Quoted All information is requested pursuant to Paragraph 53, Retention and access requirements for records, of Research Terms and Conditions, which detail the requirements for the retention of financial records, supporting documents, statistical records, and other records pertinent to NSF grant funds. Also, the subject provision requires that you provide access to these records to authorized NSF representatives.

Collaboration with Other Universities Virginia Tech UCLA Wisconsin Florida State University Next University has contacted UIUC.

Data Request 2 All Salary (all fund sources) Personnel with Appointments on NSF Individuals were selected and all salary transactions for period were provided. Files with All Personnel Payrates (one of the most challenging requests) Reconciliation of Transactions to FFRs Question on SQL Questions on Data Tables ARRA Jobs Reporting

Sample 1 First Sample November 27, 2013 205 OTPS (Other than payroll) - $56,942,695.98 70 Payroll - $967,754.04 Each line had multiple requests – an average of 4 requests. Approximately 1,100 different questions about transaction in addition to documents. Each items was reviewed and specially formatted for consistent submission. Responses were read and at times edited for more appropriate wording.

Supporting Documentation Requested Payroll Support should include (as applicable): Timesheets Other documents supporting salary allocations and/or time charges Notice of appointment letters PEIESUM Forms Salary scales Recalculation for 2/9ths Salary

Non-payroll Non-payroll – Support should include (as applicable): Purchase orders Contracts Vendor invoices Travel expense reimbursement forms Credit card bills, and receipts Support for journal entries should include documents: Supporting the original charge Documents supporting the amount, reason for, and nature of the journal entry.

Fieldwork NSF arrives with three team members on February 15, 2014. Worked at the Grants and Contract Office 8:30 a.m. to 6:30 p.m. for two weeks. Met with GCO NSF Section Head. GCO provided initial information contained in 13 large binders. Provided flash drives of all sample items.

Fieldwork (continued) Met to interview Individual PI’s Met on: Confirmations Manual Pay Adjustments Insurance Process Indirect Cost FFR Preparation and Reconciliations Each Friday throughout the rest of the engagement a status update was provided.

8 Weeks of Follow-up Questions 2/21/14 2/27/14 3/07/14 3/14/14 3/20/14 4/04/14 4/10/14 4/17/14

Sample 2 Second Sample May 5, 2014 OTPS 148 - $20,035,602.31 Payroll 27 - $261,880.39 2nd request required at least 700 documents/responses Firm expressed that they were having trouble finding an additional sample due to the number of items that were subsequently removed after GCO review.

9 Weeks of Follow-up Questions 6/05/14 6/12/14 6/20/14 7/10/14 7/17/14 7/24/14 7/29/14 7/31/14 8/06/14 8/28/14 Fieldwork Ends!

Findings Seven Findings UIUC was able to drop one additional one after the Draft report

Schedule of Questioned Costs By Finding Totaling $173,290

Common Themes of Issues Travel Especially Foreign Travel Missing Documentation Service Rates Meals/Social Events Direct Benefit to Projects

Next Steps Audit Resolution Working with NSF on Remaining Audit Items Corrective Actions Plans for Costs Removed Clarification on Others

Next Steps (continued) Policies and Procedures Being updated Looking at Uniform Guidance Working on a similar approach (Data Analytics) to Review Award Costs Computer Generated – Unallowable Review Dr. Baker at NSF has agreed to call to discuss.

Conclusion Our Internal Controls are Working There are Specific Issues We Need to Address Uniform Guidance is Coming

Questions