Florida State University Did Not Always Claim Selected Costs Charged Directly to Department of Health and Human Services Awards in Accordance With Federal Regulations and National Institutes of Health Guidelines

Based on our sample results, we estimated that, of approximately $10.6 million in transactions, Florida State University (the University) charged approximately $3 million in unallowable transactions to Department of Health and Human Services (HHS) grants, contracts, and other agreements (awards) during fiscal years 2009 and 2010. During the period October 1, 2008, through September 30, 2010, the University claimed reimbursement for approximately $37.7 million in costs incurred on 217 awards with HHS components. In addition to its regular funding through grants and contracts, the University was awarded 28 grants totaling $8.6 million in funding provided by the American Recovery and Reinvestment Act of 2009, P.L. No. 111-5.

In our sample of 100 salary transactions, 53 were allowable but 47 were not, and in our sample of 100 nonsalary transactions, 55 were allowable but 45 were not. These unallowable transactions occurred because the University did not provide adequate oversight to ensure consistent compliance with Federal regulations. Although its finance and accounting procedures often incorporated text from Federal regulations, the University largely left it to the discretion of its individual colleges, departments, and principal investigators to interpret the procedures correctly and to comply with Federal regulations. In addition, the University's Division of Sponsored Research did not review transactions to ensure that they complied with Federal regulations.

We recommended that the University (1) refund $3 million to the Federal Government and (2) enhance oversight of charges to Federal awards to ensure consistent compliance with Federal regulations. The University disagreed with our overall findings. The University also took exception to our methodology for extrapolating our sample results and conclusions about the University's internal controls.