2022-002 ? Time and Effort Documentation Federal Agency: Department of Health and Human Services Federal Program: Research and Development Cluster Assistance Listing Number: 93.310 ? Trans-NIH Research Support Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: According to Code of Federal Regulations, 200 CFR 200.430(i), the minimum time and effort documentation must be supported by a system of internal controls which provides reasonable assurance that charges are accurate, allowable and allocable; be incorporated into official records; reasonably reflect total activity for which the employee is compensated; encompass all activities (federal and nonfederal); comply with established accounting policies and practices; and support distribution among specific activities or cost objectives. Condition: We noted the charges for one employee was not supported by the established time and effort documentation. This discrepancy was noted for 1 out of 35 samples tested, which was statistically valid. Questioned Costs: $1,653 (known), $16,540 (likely) Context: The employee?s time and effort accounted for $14,887 of the $816,606 total personnel expenses charged to the program audit the award period. Cause: The employee?s time and effort on the program was not captured within the Blood Bank?s timekeeping system. Effect: The condition identified led to noncompliance with federal time and effort documentation requirement. Repeat Finding: Yes, 2021-001 Recommendation: We recommend the Blood Bank implement procedures to ensure all personnel charges to the program are supported by the minimum time and effort documentation outlined within 200 CFR 200.430. Views of Responsible Officials and Planned Corrective Actions Please refer to the attached Corrective Action Plan.
2022-003 ? Indirect Costs Based on Modified Total Direct Costs Federal Agency: Department of Health and Human Services Federal Program: Research and Development Cluster Assistance Listing Number: 93.310 ? Trans-NIH Research Support Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: According to Code of Federal Regulations, 200 CFR 200.68, the recipient must exclude rental costs from the Modified Total Direct Costs (MTDC) subject to the indirect cost rate. Condition: $96,000 rent ($8,000 a month) was included in the MTDC calculation subject the indirect cost rate. Upon testing three of the 12 monthly invoices, we further confirmed all 12 invoices included the rental costs. Questioned Costs: $9,600 (known) Context: $96,000 rent ($8,000 a month) was included in the MTDC calculation subject the indirect cost rate. Cause: MTDC calculation did not exclude rental costs. Effect: The condition identified led to noncompliance with respect to reimbursement of the rent at the 10% de minimis indirect cost rate. Repeat Finding: No Recommendation: We recommend the Blood Bank implement procedures to ensure only allowable charges outlined within 200 CFR 200.68 are included in the MTDC subject to the indirect cost rate. Views of Responsible Officials and Planned Corrective Actions Please refer to the attached Corrective Action Plan.
2022-002 ? Time and Effort Documentation Federal Agency: Department of Health and Human Services Federal Program: Research and Development Cluster Assistance Listing Number: 93.310 ? Trans-NIH Research Support Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: According to Code of Federal Regulations, 200 CFR 200.430(i), the minimum time and effort documentation must be supported by a system of internal controls which provides reasonable assurance that charges are accurate, allowable and allocable; be incorporated into official records; reasonably reflect total activity for which the employee is compensated; encompass all activities (federal and nonfederal); comply with established accounting policies and practices; and support distribution among specific activities or cost objectives. Condition: We noted the charges for one employee was not supported by the established time and effort documentation. This discrepancy was noted for 1 out of 35 samples tested, which was statistically valid. Questioned Costs: $1,653 (known), $16,540 (likely) Context: The employee?s time and effort accounted for $14,887 of the $816,606 total personnel expenses charged to the program audit the award period. Cause: The employee?s time and effort on the program was not captured within the Blood Bank?s timekeeping system. Effect: The condition identified led to noncompliance with federal time and effort documentation requirement. Repeat Finding: Yes, 2021-001 Recommendation: We recommend the Blood Bank implement procedures to ensure all personnel charges to the program are supported by the minimum time and effort documentation outlined within 200 CFR 200.430. Views of Responsible Officials and Planned Corrective Actions Please refer to the attached Corrective Action Plan.
2022-003 ? Indirect Costs Based on Modified Total Direct Costs Federal Agency: Department of Health and Human Services Federal Program: Research and Development Cluster Assistance Listing Number: 93.310 ? Trans-NIH Research Support Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: According to Code of Federal Regulations, 200 CFR 200.68, the recipient must exclude rental costs from the Modified Total Direct Costs (MTDC) subject to the indirect cost rate. Condition: $96,000 rent ($8,000 a month) was included in the MTDC calculation subject the indirect cost rate. Upon testing three of the 12 monthly invoices, we further confirmed all 12 invoices included the rental costs. Questioned Costs: $9,600 (known) Context: $96,000 rent ($8,000 a month) was included in the MTDC calculation subject the indirect cost rate. Cause: MTDC calculation did not exclude rental costs. Effect: The condition identified led to noncompliance with respect to reimbursement of the rent at the 10% de minimis indirect cost rate. Repeat Finding: No Recommendation: We recommend the Blood Bank implement procedures to ensure only allowable charges outlined within 200 CFR 200.68 are included in the MTDC subject to the indirect cost rate. Views of Responsible Officials and Planned Corrective Actions Please refer to the attached Corrective Action Plan.