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Our objective was to determine whether subaward costs claimed by Yale University (the University) under a University of Massachusetts Medical School (UMMS) grant from the National Institutes of Health (NIH) were in accordance with the terms of the subaward and applicable Federal regulations. The University claimed $193,779 in costs that did not comply with OMB Circulars A-21 and subaward terms. In addition, the Principal Investigator failed to provide the 25 percent level of effort proposed in the University’s subaward application. We recommended that the University (1) verify that cost transfers are adequately explained and documented, (2) improve procedures for direct charging of costs and comply with procedures for confirming effort reports, and (3) ensure that levels of efforts are satisfied. Because the University received its funds through a subaward from UMMS rather than directly from NIH, we will recommend under separate cover that UMMS reimburse NIH for remaining unallowable subaward costs totaling $193,779. The University acknowledges the $78,965 in disallowances and disagreed with the remaining $114,814.