oversight

Purdue University

Published by the National Science Foundation, Office of Inspector General on 2017-03-20.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                                                 At a Glance

                                    Performance Audit of Incurred Costs —

                                             Purdue University


Report No. 17-1-003, March 20, 2017


Audit Objective                            Audit Results
The National Science Foundation (NSF)
Office of Inspector General (OIG)          Costs PU charged to its NSF-sponsored agreements did not
engaged WithumSmith+Brown (WSB)            comply with Federal and NSF award requirements. The
to conduct a performance audit of          auditors questioned $91,281 of costs claimed by PU during the
incurred costs at Purdue University (PU)   audit period. Specifically, auditors found:
for the period April 1, 2012, to March        • $36,437 in unreasonable travel;
31, 2015. The audit encompassed more          • $28,984 in unreasonable expenditures;
than $238 million comprising all costs        • $25,011 in equipment, materials, and supplies
claimed to NSF. The objective of the               unreasonably purchased near the award expiration date;
audit was to determine if costs claimed            and
by PU during this period were allocable,      • $849 in insufficiently documented travel charges.
allowable, reasonable, and in conformity
with NSF award terms and conditions
and applicable Federal financial
assistance requirements.

WSB is responsible for the attached
auditor’s report and the conclusions
expressed in this report. The NSF OIG
does not express any opinion on the        Agency Response
conclusions presented in WSB’s audit
report.                                     PU disagreed with the four findings in the report. PU
                                            contends that the costs within the findings are allowable and
                                            disagreed with the auditors’ interpretation of the Federal
Recommendations                             guidance. PU also did not agree with the auditors’ statements
The auditors included four findings in      that there were weaknesses in management and
the report with associated                  administrative controls. After taking PU’s comments into
recommendations for NSF to resolve the      consideration, the auditors continue to question the costs and
questioned costs and to ensure PU           left the findings unchanged.
strengthens administrative and
management controls.                        Although PU disagreed with the fourth finding, it concurred
                                            it did not have adequate documentation to support the
                                            claimed costs.
Contact Information
                                            PU’s response is attached in its entirety to the report as
For further information, contact the NSF
                                            Appendix A.
OIG at (703) 292-7100 or oig@nsf.gov.
                         National Science Foundation • Office oflnspector General
                         4201 Wilson Boulevard, Suite I-1135, Arlington, Virginia 22230

MEMORANDUM 


Date:             March 20, 2017

To:               Dale Bell
                  Director, Division of Institution and Award Support

                  Jamie French
                  Director, Division of Grants and Agreements


From: 	           Mark Bell
                  Assistant Inspector General, Office of Audits

Subject: 	        Audit Report No. 17-1-003
                  Purdue University

This memo transmits the WithumSmith+Brown (WSB) report for the audit of costs totaling
approximately $238 million charged by Purdue University to its sponsored agreements with the
National Science Foundation (NSF) during the period April 1, 2012, to March 31 , 2015. The
objective of the audit was to determine if costs claimed by Purdue University during this period
were allocable, allowable, reasonable, and in conformity with NSF award terms and conditions
and applicable Federal financial assistance requirements.

In accordance with Office of Management and Budget Circular A-50, Audit Followup, please
provide a written corrective action plan to address the report recommendations. In addressing the
report's recommendations, this corrective action plan should detail specific actions and
associated milestone dates. Please provide the action plan within 60 calendar days of the date of
this report.

OIG Oversight of Audit

To fulfill our responsibilities under generally accepted government auditing standards, the Office of
Inspector General:

      •	   reviewed WSB 's approach and planning of the audit;
      •	   evaluated the qualifications and independence of the auditors;
      •	   monitored the progress of the audit at key points;
      •	   coordinated periodic meetings with WSB and NSF officials, as necessary, to discuss audit
           progress, findings, and recommendations;
    • 	 reviewed the audit report prepared by WSB to ensure compliance with generally accepted
        government auditing standards; and
    • 	 coordinated issuance of the audit report.

We thank your staff for the assistance that was extended to the auditors during this audit. If you
have any questions regarding this report, please contact Billy McCain at 703-292-4989.

Attachment

cc: 	   Alex Wynnyk, Staff Associate for Oversight, DIAS
        Rochelle Ray, Branch Chief, Resolution and Advanced Monitoring Branch, DIAS
        John Anderson, Chair, Oversight Committee, NSB
        Christina Sarris, Assistant General Counsel, OD
        Ken Chason, Counsel to the Inspector General, OIG




                                                  2

              Purdue University

         Audit of Incurred Costs for

     National Science Foundation Awards

For the Period April 1, 2012 to March 31, 2015

TABLE OF CONTENTS



                                                                                                                                                        Page

Independent Auditors’ Report....................................................................................................................... 1

Results in Brief ............................................................................................................................................. 1

Findings and Recommendations ................................................................................................................... 2

Appendix A: Awardee Response ................................................................................................................ 10

Appendix B: Objectives, Scope, and Methodology .................................................................................... 13

Appendix C: Questioned Cost Summary by Award ................................................................................... 14





ACRONYMS

 CFR                            Code of Federal Regulation
 DIAS                           Division of Institution and Award Support
 NSF                            National Science Foundation
 OIG                            Office of Inspector General
 OMB                            Office of Management and Budget
 PI                             Principal Investigator
 Purdue                         Purdue University
 SC                             Steering Committee
Independent Auditors’ Report

The National Science Foundation (NSF) is an independent Federal agency created by the National Science
Foundation Act of 1950 (P.L. 810-507). Its mission is “to promote the progress of science; to advance the
national health, prosperity, and welfare; and to secure the national defense.” NSF is also committed to
ensuring an adequate supply of the Nation’s scientists, engineers, and science educators. NSF funds
research and education in science and engineering by awarding grants and contracts to educational and
research institutions in all parts of the United States. Through grants, cooperative agreements, and contracts,
NSF enters into relationships with non-federal organizations, including Purdue University (Purdue), to fund
scientific research and educational initiatives.

Purdue is a multi-campus system designed to address the post-secondary educational needs in Indiana. In
fiscal year 2015, Purdue received $401 million in research and sponsored program awards. NSF was the
largest single contributor at $67 million. Because Purdue receives significant NSF awards, the NSF Office
of Inspector General (OIG) selected Purdue for audit.

WithumSmith+Brown, under contract with the NSF OIG, audited the costs claimed by Purdue on NSF
awards for the period beginning April 1, 2012, and ending March 31, 2015. The audit objective was to
determine whether the costs claimed were allowable, allocable, and reasonable in conformity with NSF
award terms and conditions and applicable Federal financial assistance requirements.

We conducted this performance audit in accordance with generally accepted government auditing
standards, which require that we plan and perform the audit to obtain sufficient, appropriate evidence to
provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit
objectives. Our objectives, scope, and methodology are detailed in Appendix B.

Results in Brief

To aid in determining reasonableness, allowability, and allocability of costs, we obtained from Purdue all
award transactions comprising costs claimed on NSF awards during the period of April 1, 2012, through
March 31, 2015. This provided an audit universe of approximately $238 million, in approximately 494,000
transactions, across 892 individual NSF awards. For transaction testing, we judgmentally selected 252
transactions totaling $2.16 million and utilized a data analytics approach to identify potential risk areas. We
also performed additional non-transaction based tests as we deemed necessary.

Of the $2.16 million in the transaction testing, our audit questioned $91,281 of costs claimed on seven NSF
awards because Purdue did not comply with Federal and NSF award requirements. Specifically, we noted:
$36,437 in unreasonable travel; $28,984 in unreasonable expenditures; $25,011 in equipment, materials,
and supplies unreasonably purchased near the award expiration date; and $849 in insufficiently documented
travel charges. These questioned costs resulted in four areas identified where Purdue’s controls could be
improved to ensure compliance with laws and regulations. Purdue did not agree with the questioned costs.
The findings are outlined in our report and presented by award in Appendix C. Additional information
concerning the questioned items was provided separately by the OIG to the Division of Institution and
Award Support, Resolution and Advanced Monitoring Branch.




                                                                                                             1
Findings and Recommendations

Finding 1 – Unreasonable Travel

We questioned $36,437 charged to one NSF award for Principal Investigator (PI) travel that did not appear
to benefit the award and was not reasonable or prudent. The travel expenditures were not consistent with
the objectives stated in the award.

According to 2 Code of Federal Regulation (CFR) 220 (OMB Circular A-21), Appendix A, Section C, to
be allowable for a Federal grant, a cost must be allocable to the Federal award and be necessary and
reasonable for the administration and performance of the award. Furthermore, Appendix A, Section C.3,
provides that a reasonable cost is one that a “prudent person would have incurred under similar
circumstances.”

The primary focus of this award was to develop a software institute at Purdue dedicated for specific
purposes. At NSF’s request, Purdue reduced the proposed project from $610,978 to $200,000. With this
reduction, NSF requested that the award focus on institute activities, rather than the technical development
activities. In the budget impact statement, Purdue stated that they would focus on activities aimed at
identifying the key properties of the institute by meeting with representatives of various organizations. The
institute was to be physically located at Purdue and included a PI team, a Steering Committee (SC), and the
participation of the NSF-funded Center for the Science of Information.

The original “other direct costs” budget category included $10,500 for graduate fee remissions and
$140,000 for conference-related expenses including food, room reservation, and travel for invited speakers,
PIs, and SC members. As part of the reduction to focus on the institute, the other direct cost budget category
was reduced to $95,319, which included $10,416 for graduate fee remissions and $84,903 for funding to
host conference meetings for the PIs and SC members.

Although there was no travel in the award budget, $54,950 was spent on PI travel during our audit period.
Our audit tested $29,968 in PI travel and questioned $22,492. Per Purdue, the travel expenditures were
approved through the “other direct costs” line item; however, our assessment of the award focus and
proposal found that those funds were to be used for institute-related conference events. The questioned
travel appeared to be non-institute related travel that was more focused on the PI’s development rather than
the development of the institute.

We found that the PI was on sabbatical from August 13, 2012, through May 12, 2013. The documented
reason for the sabbatical was to work with individuals on a joint project for the development of the next
generation language for data analytics. This focus on the development of the next generation language does
not appear to be related to the development of the institute. Per the sabbatical request, being co-located with
the other investigators was crucial during the early stages of the work. Although these individuals appear
to be headquartered in California, the PI charged NSF for trips to Paris, France; Kyoto, Japan; Rome, Italy;
Hawaii; Arlington, Virginia; Tucson, Arizona; Santa Cruz, New Mexico; Chicago, Illinois; Annapolis,
Maryland; and back to Purdue during the sabbatical.

Reallocating 33 percent of the total direct costs for non-institute related PI travel is not reasonable, prudent,
or consistent with the stated award objectives. This travel was not related to the NSF-funded workshops
and events per the revised proposal budget. The presentations at various conferences, workshops,
educational institutions, and corporations were mentioned in the annual report1 for the period ending
September 30, 2013. However, no international travel was included in the annual or the final reports

1
    Annual and final reports are submitted to NSF to address the progress of a project.
                                                                                                               2
submitted to NSF. We identified nine travel transactions, totaling $34,638 ($22,492 plus $12,146 associated
indirect costs), that appear to be outside the award scope of establishing a software center at Purdue. We
note that several of the trips took place during the PI’s sabbatical period, which was granted for purposes
unrelated to the objectives of the NSF award. The following summarize the questioned travel costs:

       $6,015 for travel to Rome, Italy, and Linz, Austria, from January 21-29, 2013, to present a paper,
        give a talk, attend a meeting, and meet with a company in Austria. The PI was on sabbatical during
        this trip;
       $5,287 for travel to Geneva, Switzerland; Prague, Czech Republic; and London, England from
        August 19 to September 9, 2013, to collaborate with other researchers;
       $5,212 for travel to a university in Zurich, Switzerland, from October 3-7, 2013, to give a
        presentation;
       $3,840 for travel to Paris, France, from September 24-30, 2012, to give a presentation at a university
        in Paris, participate in a Higher Degree Research (HDR) committee and meet with other
        researchers. The PI was on sabbatical during this trip;
       $3,142 for travel to Boston, Massachusetts, from September 26-30, 2013, to attend a Special
        Interest Group on Programming Languages (SIGPLAN) Executive Meeting;
       $2,924 for travel to Kyoto, Japan, from December 8-14, 2012, to attend the Asian Symposium on
        Programming Languages and Systems (APLAS) Conference where he was a keynote speaker. The
        PI was on sabbatical during this trip;
       $2,898 for travel to Zurich, Switzerland, from October 3-10, 2013, to visit a university to
        collaborate with other researchers;
       $2,871 for travel to San Francisco from November 8-13, 2013, to visit Oracle Research and
        Stanford to further his collaboration towards the implementation of the R language; and
       $2,449 for travel to Annapolis, Maryland, from May 6-8, 2013, to attend the High Confidence
        Software and Systems Conference (HCSS) as a guest speaker. The PI was on sabbatical during this
        trip.

Additionally, we questioned $1,799 ($1,168 plus $631 associated indirect costs) for expenses related to
personal time and a rental car charged to the NSF award during a trip to Hawaii from December 31, 2013,
to January 7, 2014. Purdue stated, “The words ‘Personal Day’ for the day 12/31 were typed on the line for
1/1 as there was no space available to type that information on the line for 12/31,” but the documentation
states that the employee was “taking 2 days off with kids before the event starts.” Therefore, we questioned
$1,147 for the personal expenditures charged to the NSF award. We also found that there were two rental
cars charged to the NSF award and questioned $652 for the extra rental car. It is unreasonable to charge the
NSF award for personal days and two rental cars.
Purdue personnel did not adequately review the expenditures charged to NSF awards, which resulted in
unreasonable travel costs. Without an effective process in place to ensure the reasonableness of the travel
costs and consistency with the award objectives, there is the increased risk that funds may not be used as
required to accomplish the necessary project objectives in accordance with Federal and NSF requirements.

Recommendation 1:

We recommend that the NSF’s Director of the DIAS address and resolve the following Purdue
recommendations:

      1) Work with NSF to resolve the $36,437 of questioned costs; and
      2) Strengthen the administrative and management controls and processes for reviewing and
          approving costs charged to NSF awards for travel expenditures.
Summary of Awardee Response:

                                                                                                            3
Purdue disagreed with our findings and recommendations and maintained that adequate evidence was
provided. Per the university, the travel costs benefited the award and were reasonable and necessary in
accordance with Federal cost principles. The costs were necessary to accomplish the objectives of the
revised budget impact statement of the project. The processes for reviewing and approving expenditures
were appropriate and there are no administrative and management control weaknesses. For the costs
questioned, Purdue provided a detailed response as to why the institution believes the costs were necessary
and reasonable and how they benefited the award.

See Appendix A for the complete Purdue response.

Auditor Comments:

For these costs that Purdue disagreed with, our conclusions remain unchanged. The additional information
provided by Purdue did not change our view, as noted above in Finding 1, that these costs should be
questioned. NSF requested that the award focus on institute activities, rather than the technical development
activities. The questioned travel was not reasonable, prudent, or related to the NSF-funded workshops and
events per the revised proposal budget. Therefore, the report finding and recommendations remain as stated.


Finding 2 – Unreasonable Expenditures

We found $28,984 of unreasonable transactions charged to two NSF awards that were not in accordance
with Federal cost principles.

According to 2 CFR 220, Appendix A, Section C, to be allowable for a Federal grant, a cost must be
allocable to the Federal award and be necessary and reasonable for the administration and performance of
the award. Section C.3 of 2 CFR 220 provides that a reasonable cost is one that a “prudent person” would
have incurred under similar circumstances. Additionally, Section C.4 of 2 CFR 220 states that a cost is
allocable to a sponsored agreement if it is incurred solely to advance the work under the sponsored
agreement or it benefits both the sponsored agreement and other work of the institution in proportions that
can be approximated through use of reasonable methods. The recipient institution is responsible for
ensuring that costs charged to a sponsored agreement are allowable, allocable, and reasonable under these
cost principles.

2 CFR 215.21 (OMB Circular A-110) states that recipients’ financial management systems shall provide
for accurate, current, and complete disclosure of the financial results of each Federal sponsored project.

Specifically, we questioned $18,480 charged for access to an outside laboratory in Italy. The annual fee
was not explicitly budgeted in the proposal. Per the “Facilities, Equipment and Other Resources” statement
in the award proposal, access to this laboratory was necessary and available. According to the NSF Grant
Proposal Guide, resources in the Facilities statement are not considered cost sharing; however, the
Foundation does expect that the resources identified will be provided, or made available, should the
proposal be funded. Per Purdue, this was simply an omission in this first proposal written by the PI. The
current grant that NSF awarded to the PI for similar research does include the facility fee in the budget
justification. Previous fees had been paid for by the PI from other funds, but once this grant became
available, the PI used the NSF funds for this fee. It is not reasonable to charge NSF the $18,480 ($12,000
plus $6,480 associated indirect costs) for resources the proposal indicated were already available.

We also questioned $10,504 ($7,244 plus $3,260 associated indirect costs) charged to the NSF award 3 ½
months after the award expired in May 2013. The general supplies were purchased between November
2010 and August 2012 and were not identified and posted to the NSF award until 3 months after the award
expiration. Per Purdue, when it was discovered that the identified lab supplies had not been ordered using

                                                                                                           4
the NSF award account number, the Co-PI met with the lab manager, and they reviewed all orders placed
on the general fund during the life of the NSF award to identify orders used on the NSF project. A hand-
written list of orders to be charged to the NSF award was developed. Purdue also stated that the lab manager
was responsible for ordering supplies, but neither the Co-PI, lab manager, nor campus officials were
familiar with sponsored program processes and therefore failed to charge the supplies to the NSF award.
The error was not discovered until closing out the NSF Award. Given the circumstances under which these
charges were identified, we question the reliability of retroactively determining whether general supplies
were used on a project years after the supplies were purchased.

Purdue personnel did not adequately review the expenditures charged to NSF awards, which resulted in
unreasonable costs. Without an effective process in place to ensure the reasonableness of supplies expenses,
there is the increased risk that funds may not be used to accomplish the necessary project objectives in
accordance with Federal and NSF requirements.

Recommendation 2:

We recommend that the NSF’s Director of the DIAS address and resolve the following Purdue
recommendations:

        1) Work with NSF to resolve the $28,984 of questioned costs; and
        2) Strengthen the administrative and management controls and processes for reviewing and
           approving supplies charged to NSF awards.

Summary of Awardee Response:

Purdue disagreed with our findings and recommendations and maintained that adequate evidence was
provided. Purdue believes that the use of NSF funds for the laboratory fee was allowable, allocable, and
reasonable for carrying out the research proposed and are permitted as part of the University’s rebudgeting
authority. The lab supplies charged to the award during the closeout process benefitted the students and,
therefore, benefitted the award charged and were reasonable and necessary in accordance with Federal cost
principles. Per Purdue, the processes for reviewing and approving expenditures were appropriate, and there
are no administrative and management control weaknesses. For each of the costs we questioned, Purdue
provided a detailed response as to why the institution believes the costs were necessary and reasonable and
how they benefited the awards.

See Appendix A for the complete Purdue response.

Auditor Comments:

For these costs that Purdue disagreed with, our conclusions remain unchanged. The additional information
provided by Purdue did not change our view, as noted above in finding 2, that these costs should be
questioned. The resources listed in the award budget are expected to be provided, or made available, should
the proposal be funded. Also, we continue to question the reliability of retroactively identifying general
supplies used on a project years after the supplies were purchased. Therefore, the report finding and
recommendations remain as stated.


Finding 3 – Equipment, Materials, and Supplies Unreasonably Purchased near Award Expiration

We found that equipment, materials, and supply expenses totaling $25,011 charged to three NSF awards
were not necessary or reasonable in accordance with Federal cost principles.

                                                                                                          5
According to 2 CFR 220, Appendix A, Section C, to be allowable for a Federal grant, a cost must be
allocable to the Federal award and be necessary and reasonable for the administration and performance of
the award. Section C.3 provides that a reasonable cost is one that a “prudent person” would have incurred
under similar circumstances.

The Award and Administration Guide, Chapter V, Section A.2.c states that a grantee should not purchase
items of equipment, computing devices, or restock materials and supplies where there is little or no time
left for such items to be utilized in the actual conduct of the research. Therefore, we questioned $25,011 on
three awards for equipment purchased near the award expiration date that did not appear to benefit the
awards or that did not appear reasonable or prudent considering the limited time remaining on the awards.

Specifically, we questioned $11,928 for the purchase of a Linux Work Station, at the end of the career
development award, used in developing and examining algorithms. Per Purdue, they were testing the
algorithms and applying them to real data. The intensive computation and large volumes of data demanded
a new server to complete the job. The installation was completed with the aim of finalizing project research.
However, this server was purchased on April 4, 2014, on a 5-year award that expired on May 31, 2014. The
equipment was available for only 3 percent of the grant life (57 out of 1,825 days).

Additionally, we questioned $10,574 charged at the end of the career development award. The award period
was initially scheduled to conclude on July 31, 2012, but a no-cost extension was granted to July 31, 2013.
In March 2013, NSF notified Purdue that the award would expire on July 31, 2013, and that they may
request a 2-month, no-cost extension to extend the award to September 30, 2013. Because the funding was
from the FY 2007 Federal appropriation, the unspent funds would expire on September 30, 2013. Also in
March 2013, Purdue indicated to NSF that it still had unspent funds. In May 2013, Purdue requested and
received approval from NSF for another extension, to September 30, 2013.

       $8,519 for the purchase of an accessory to a laboratory device. The accessory invoice was dated
        July 25, 2013, on a 6-year award that expired on September 30, 2013. The equipment was available
        for only 3 percent of the grant life (67 out of 2,251 days);
       $2,055 ($1,352 plus $703 associated indirect costs) for 40 percent of the purchase of an Apple
        computer. The computer was received on August 5, 2013, on a 6-year award that expired on
        September 30, 2013. The computer was available for only 2 percent of the extended grant life (56
        out of 2,251 days) and appears to have been purchased to spend down expiring funds.

We also questioned $2,509 ($1,845 plus $664 associated indirect costs) for 90 percent of the purchase of a
MacBook Air that was shipped on March 1, 2013, on a 6-year award that expired on April 30, 2013. Per
Purdue, the laptop was needed to engage in meetings in preparation for the final annual meeting and to
finalize the data compilations for the report. In addition, it was needed to communicate with individuals on
the project that were difficult to communicate with over the phone, at all hours and multiple locations.
However, based on the purchase date, the general purpose laptop was not necessary for the performance
and administration of the NSF award. The computer was available for less than 3 percent of the grant life
(60 out of 2,190 days).


Purdue personnel did not adequately review the expenditures charged to the NSF awards, which resulted in
unreasonable costs. Without an effective process in place to ensure the reasonableness of equipment,
materials, and supplies expenses, there is the increased risk that funds may not be used as required to
accomplish the necessary project objectives in accordance with Federal and NSF requirements.

Recommendation 3:


                                                                                                           6
We recommend that the NSF’s Director of the DIAS address and resolve the following Purdue
recommendations:

        1) Work with NSF to resolve the $25,011 of questioned costs; and
        2) Strengthen the administrative and management controls and processes for reviewing and
           approving equipment, materials and supplies charged to NSF awards.

Summary of Awardee Response:

Purdue disagreed with our findings and recommendations and maintained that adequate evidence was
provided. Purdue believes that the questioned costs benefitted the awards charged and were reasonable and
necessary in accordance with Federal cost principles. Per Purdue, the processes for reviewing and approving
expenditures were appropriate and there are no administrative and management control weaknesses. For
each of the costs we questioned, Purdue provided a detailed response as to why the institution believes the
costs were necessary and reasonable and how they benefited the awards.

See Appendix A for the complete Purdue response.

Auditor Comments:

For these costs that Purdue disagreed with, our conclusions remain unchanged. The additional information
provided by Purdue did not change our view that these purchases near the various award expiration dates,
as noted above in Finding 3, should be questioned. A grantee should not purchase items of equipment,
computing devices, or restock materials and supplies where there is little or no time left for such items to
be utilized in the actual conduct of the research. These purchases were available for less than 3 percent of
the grant lives. Therefore, the report finding and recommendations remain as stated.


Finding 4 – Inadequate Documentation

We found $849 charged to an award for lodging expenses that did not have adequate documentation in
accordance with Federal cost principles.

According to 2 CFR 220, Section A, “the accounting practices of individual colleges and universities must
support the accumulation of costs as required by the principles, and must provide for adequate
documentation to support costs charged to sponsored agreements.”

Several attendees at a 2-day event charged 4 nights of lodging expenses to the NSF award. Per an email
sent to the conference attendees, the award would “cover a third night for international travelers and a fourth
if a Saturday stay results in a considerable airfare savings.” We requested documentation to support the
savings analysis for the fourth night of lodging, but no documentation was maintained or provided.

Per Purdue, “Further review of all airfare reimbursements was completed. When reimbursing airfare
expenses, a cost comparison was not completed at the time of the transaction. Thus, there are no records
documenting the savings of a later departure date versus the cost of an additional night of lodging. At this
late date, it is not possible to provide a cost comparison of airfare costs for flights booked in 2012.”

Purdue did not provide adequate documentation to support the fourth night of lodging expenses charged to
the NSF award and we find the fourth night to be excessive; therefore, the costs are questioned.

Purdue personnel did not adequately document the reason for the additional nights charged to the NSF
award, which resulted in this unreasonable charge. Without an effective process in place to ensure the proper
                                                                                                             7
documentation and monitoring of award expenditures, there is the increased risk that funds may not be
spent in accordance with Federal requirements.

Recommendation 4:

We recommend that the NSF’s Director of the DIAS address and resolve the following Purdue
recommendations:

    1) Work with NSF to resolve the $849 of questioned costs; and
    2) Strengthen the administrative and management controls and processes for reviewing and approving
       support for costs charged to NSF awards.

Summary of Awardee Response:

Purdue does not agree that costs of $849 for lodging charges should be disallowed, but did concur that
adequate comparative documentation supporting “considerable airfare savings” had not been provided.

See Appendix A for the complete Purdue response.

Auditor Comments:

For these costs that Purdue disagreed with, our conclusions remain unchanged. The additional information
provided by Purdue did not change our view, as noted above in Finding 4, that these costs should be
questioned. Adequate documentation to support the savings for the additional day was not provided.
Therefore, the report finding and recommendations remain as stated.




WithumSmith+Brown, PC
March 13, 2017




                                                                                                      8

APPENDICES





              9
                   APPENDIX A
AWARDEE RESPONSE




                           10
                   APPENDIX A
AWARDEE RESPONSE




                           11
                   APPENDIX A
AWARDEE RESPONSE




                           12
                                                                                               APPENDIX B
OBJECTIVES, SCOPE, AND METHODOLOGY

The objective of this audit was to determine whether claimed costs were allowable, allocable, and
reasonable with respect to NSF award terms and conditions and applicable Federal financial assistance
requirements. Our audit included assessing the allowability, allocability, and reasonableness of costs
claimed by Purdue through the Award Cash Management Service for the 3-year period beginning April 1,
2012, through March 31, 2015. The audit was performed in accordance with Government Auditing
Standards for performance audits.

To aid in determining reasonableness, allowability, and allocability of costs, we obtained from Purdue all
award transactions comprising all costs claimed to NSF during the period of April 1, 2012, through March
31, 2015. This provided an audit universe of approximately $238 million, in approximately 494,000
transactions, across 892 individual NSF awards. For transaction testing, we judgmentally selected 252
transactions totaling $2.16 million and utilized a data analytics approach to identify potential risk areas. We
also performed additional non-transaction based tests as we deemed necessary.

Our work required reliance on computer-processed data obtained from Purdue and NSF. At our request,
Purdue provided detailed transaction data for all costs charged to NSF awards during our audit period. We
also extracted award data directly from NSF’s various data systems. To select transactions for further
review, we designed and performed automated tests of Purdue and NSF data to identify areas of risk and
conducted detailed reviews of transactions in those areas.

We assessed the reliability of the data provided by Purdue by: 1) comparing costs charged to NSF award
accounts within Purdue’s accounting records to reported net expenditures, as reflected in Purdue’s quarterly
financial reports and cash requests submitted to NSF for the corresponding periods; 2) performing general
ledger to sub-ledger reconciliations of accounting data; and 3) reviewing and testing the parameters Purdue
used to extract transaction data from its accounting records and systems.

Based on our testing, we found Purdue’s computer-processed data sufficiently reliable for the purposes of
this audit. We did not review or test whether the data contained in, or controls over, NSF’s databases were
accurate or reliable; however, the independent auditors’ report on NSF’s financial statements for fiscal
years 2014 and 2015 found no reportable instances in which NSF’s financial management systems did not
substantially comply with applicable requirements.

In assessing the allowability of costs claimed to NSF by Purdue, we also gained an understanding of the
internal controls applicable to the scope of this audit through conducting interviews with Purdue, reviewing
policies and procedures, and conducting walkthroughs as applicable.

We assessed Purdue’s compliance with the University’s internal policies and procedures, as well as the
following:

       2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements
        for Federal Awards;
       2 CFR Part 220, Cost Principles for Educational Institutions (OMB Circular A-21);
       2 CFR Part 215, Uniform Administrative Requirements for Grants and Agreements with Institutions
        of Higher Education, Hospitals, and Other Non-Profit Organizations (OMB Circular A-110);
       NSF Proposal and Award Policies and Procedures Guide (includes the Grant Proposal Guide and
        Award and Administration Guide);

       NSF Award Specific Terms and Conditions; and

       NSF Federal Demonstration Partnership Terms and Conditions.



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                                                                                    APPENDIX C
QUESTIONED COST SUMMARY BY AWARD

                                                Amount          Overhead
    Award ID            ARRA Flag                                                 Total Questioned
                                               Questioned       Questioned


 Finding 1 – Unreasonable Travel
 1216853                                   $          23,660    $       12,777       $       36,437

 Finding 1 Total                                      23,660            12,777               36,437


 Finding 2 – Unreasonable Expenditures
 1206061                                              12,000             6,480               18,480
 0941921                                               7,244             3,260               10,504
  Finding 2 Total                                     19,244             9,740               28,984


 Finding 3 – Equipment, Materials, and Supplies Unreasonably Purchases Near Award Expiration
 0844945                  ARRA                       11,928                   -              11,928
 0644915                                               9,871               703               10,574
 0703443                                               1,845               664                2,509
  Finding 3 Total                                     23,644             1,367               25,011


 Finding 4 – Inadequate Documentation
 0953433                                                849                   -                849
 Finding 4 Total                               $        849         $         -          $     849




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