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THE VANDERBILT UNIVERSITY OMB Circular A-133 Reports Year ended June 30, 2006 EIN: 62-0476822 - page 54 / 54

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THE VANDERBILT UNIVERSITY Schedule of Findings and Questioned Costs Year ended June 30, 2006

Recommendation

The University should develop enhanced internal controls and a monitoring policy for federal salary

limitations.

There should be specified

administrative

(F&A)

expenditures

on

personnel a monthly

that monitor NIH salary, basis to ensure that all

fringe, and facilities University employees

cap and are

compliant. In addition, designated departmental personnel should be appropriately trained calculate whether an employee has exceeded the salary limitation threshold and continuously results to ensure all employees are compliant at the end of each fiscal year.

on how to monitor the

Management’s Response

The issue referenced above relating to the NIH imposed salary cap has been addressed. The University performed a 100% review for FY 2006 of all persons over the salary cap that were paid from NIH monies, and will have corrected any grants which had been inadvertently overcharged by making the appropriate adjusting journal entries in order to reimburse the difference by December 31, 2006. The University has developed procedures within the central accounting offices to monitor the NIH salary cap on a quarterly basis and is working closely with departmental administrators to ensure they understand the salary limitations on NIH awards.

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